United States
           Region 4
                             .,
Environmental Protection  345 Courtland Street, NE  EPA 904/9-93-001 B {/
Agency        Atlanta, GA 30365    November 1993
Appendix to the
Environmental
Impact Statement
                         Final
Cedar Bay Cogeneration Project
Jacksonville, Florida

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0

                         APPENDIX A

          DRAFT NPDES PERMIT NO. FL0061204
                                  U.S. Environmental Protection Agency
                                  Region 5, Library ;PL-12J)
                                  77 West Jackson Boulevard, 12th Floor
                                  Chicago, IL  60604-3590

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                                    PERMIT NO.  FL0061204
                                    Minor Non-POTW

       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         REGION IV
           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"),

       Cedar Bay  Cogeneration, Inc.
       7475  Wisconsin Avenue
       Bethesda,  Maryland  20814


is authorized  to  discharge from a facility  located at

       Cedar Bay  Cogeneration Facility
       9469  Eastport Road
       Duval County         ; "
       Jacksonville, Florida  32218


to receiving waters  named
                                                        •
       Broward River


in accordance with effluent  limitations,  monitoring
requirements,  and other conditions set forth herein.,  Thf
permit consists of this cover sheet, Part I 3 pages, Part II
1& pages, Part III 2. pages and  Part IV 8  pages.


       This permit shall become effective on


       This permit and the authorization to discharge shall
       expire at midnight,



                               DRAFT

                                  0 3 1993
 Date Issued             W. Ray Cunningham, Director
                         Water Management Division
                           A-l

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                                                    ;          :     '               Page  1-1
                                                                                  Permit No.  FL0061204
                                       •:=r-.!;*'•• ' '!-.  PART:-I - •:-•-••-  • "  ~   .\\  -'  • • _  .
  A.   EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS-- -FINAL —r    ;   :•;  !        :-.; ; : ".'•

  1.   During the period beginning on the effective date of this permit  and lasting  through the term of
      this permit, the permittee is authorized to discharge - ground runoff, roof and yard drain
      discharges from the Yard Area Runoff Pond Outfall 003 to the Broward River.

      Such discharges shall be limited and monitored by the permittee as specified  below:

  PARAMETERS                        DISCHARGE LIMITATIONS  MONITORING REQUIREMENTS
                                    Daily Maximum          Measurement  Frequency      Sample Type

  Flow,  MGD                              Report            I/Day of  Discharge         Weir measurement (t
  Total  Suspended Solids, mg/1           Report            I/Day of  Discharge         Grab              x~"'



  2.   The pH shall not be less than 6.0 standard units nor greater than 8.5 standard units and shall
      be monitored I/day of discharge.

  3.   There shall be no discharge of floating solids or visible foam in other than  trace amounts nor
      shall the effluent cause a visible sheen on the receiving water.

  4.   Monitoring requirements are not applicable during periods of no discharge.

  5.   Samples taken in compliance with the monitoring requirements specified above-shall be taken at
      the following location(s): point(s) of discharge from the Yard Area Pond to the Broward River   :
      prior to mixing with any other waste stream.
TO
 \
                                                              \

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                                                                                 Page 1-2
                                    ••;.,•;                  '!   '.;,--.;...          -Permit No* FLO 0612 04

                                                 PART I

B.  EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS  - FINAL        • v.' •••--         !"••'•  --   r
                                     ,-.'-,. ...'. .-  - -V ,,.:-..'••           ..
1.  During the  period beginning on the effective date of  this permit and lasting through the term
    of this permit,  the permittee is authorized to discharge  from Outfall 008 - Coal, Limestone,
    and Ash Storage  Areas Runoff Retention Basin:effluent to  the1 Broward River.    ;r:   - -,

    Such discharges  shall be limited and monitored by the permittee as specified below:, ,

PARAMETERS                         DISCHARGE LIMITATIONS     MONITORING REQUIREMENTS
                                   Instantaneous Maximum     Measurement Frequency    Sample  Type

Flow, MGD                               Report               1/Day of Discharge       Weir
                                                                                      measurement

Total Suspended Solids, mg/1           501                  I/Day of Discharge       Grab


2.  The pH shall not be less than 6.0 standard units  nor  greater than 8.5 standard units, and  shall
    be monitored once per day of discharge by grab sample.

3.  There shall be no discharge of floating solids or visible foam in other than trace  amounts nor
    shall the effluent cause a visible sheen on the receiving water.

4.  Samples taken in compliance with the.monitoring requirements specified above'shall  be taken  at
    the following location(s): point(s) of discharge  from the Coal, Limestone, and Ash  Retention
    Basin prior to mixing with any other waste stream.

                                                  - ' : .         :           •       "    \
1 This limitation is only applicable to flow, resulting from.the 10-year, 24-hour storm  event,  or
    less.                      •'   .'''"'."  ..'-"  ' '  -"':v      '  vv"'   '     ,  ;       •'  .... V ''.,'.
                                .',,,  ..:<••• rvl '•:•;'•••. •'• •;   • • •''"   !'•!>• ••••;•••:••  .••;••:•  .:.•••.;.... <•),_. -.;-..[. -•',/- .

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                                            Page 1-3
                                            Permit No. FL0061204
                                 PART I
C.  SCHEDULE OF COMPLIANCE
1.  The permittee shall achieve compliance with the effluent
    limitations specified for discharges in accordance with the
    following schedule:                                   "  ,•

    a.  Operational Level Attained	Commencement of Discharges

 t  b.  Best Management Practices Plan (Part. IV)

      (1)  Develop Plan	No later than 6 months after
                                        the effective date of the
                                        permit     •

      (2)  Implement Plan..	No later than 18 - months after
                               .,'--  the effective date of the
                                        permit

 v  a;  Submittal.of EPA Form 2C...../.. .No lat^r than 2 years from
 :                                      the commencement of         *
                                        discharge


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, any remedial actions taken, and the
    probability of meeting the next scheduled requirement.

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                                                           Part II
                                                           Page II-l
                                     PART II

              STANDARD CONDITIONS FOR  "NO DISCHARGE" NPDES PERMITS
SECTION A.  GENERAL CONDITIONS
^^••^^^^••^^^^^^^"•^••"•^•^^^^^^••^^^^^—•^"^^•"^^^•^^^^^^•"l»                 ^

1.   Duty to Comply

The  permittee must  comply  with all  conditions of  this permit.   Any permit
noncompliance  constitutes a violation  of the Clean  Water Act  and  is grounds
for  enforcement  action; for permit  termination,  revocation and reissuance, or
modification; or for denial of a permit renewal application.

2.   Penalties for Violations of Permit Conditions

Any person  who violates a permit condition is subject to  a  civil penalty  not
to  exceed  $25,000  per  day of such   violation.   Any  person-  who  willfully
violates permit  conditions is  subject  to  a fine of  not less  than $5000  nor
more than $50,000  per  day of violation, or by imprisonment for  not  more than  3
years,  or   both.   Any  person who  negligently  violates  permit  conditions is
subject  to  a  fine of  not  less than  $2500 nor  more  than $25,000  per day of
violation, or by imprisonment for not more  than  1 year, or  both.

3.   Duty to Mitigate

The  permittee  shall  take  all  reasonable  steps to  minimize  or orevent  any
violation  of  this permit which  has   a  reasonable  likelihood  of  adversely
affecting human health  or the enviroment.

4.   Permit Modification

After  notice  and  opportunity  for  a  hearing,   this  permit   may be  modified,
terminated or revoked for cause  including,  but not  limited to, the following:

     a.  Violation of any terms  or conditions of this permit;

     b.  Obtaining  this  permit by  misrepresentation  or  failure to  disclose
         fully all relevant facts;

     c.  Information   newly  acquired   by   the  Agency   indicating  that  any
         condition poses a threat to human  health or the environment.
                              A-5

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                                                             Part  II
                                                             Page  II-2
 If the permittee  believes  that  any past - planned activity would be cau^e f-,-
 modification  or revocation and  reissuance under 40 CFR  122.62,  the permtr«»«
 must  report such  information to the Permit  Issuing Authority.   The SSnitta'
 of a  new  application  may be  required  of the  permittee.   The  filing of  I
 request  by  the permittee for  a  permit modification, revocation and reisluanc-"
 or  termination   or   a  notification  of  planned   changes   or  anticipated
 noncompliance, does not  stay any permit condition.                  anticipatea

 5.  Civil and Criminal Liability

Except as  provided in  permit conditions  on  "Bypassing"  Section  a

B~3JndJ^SetS\ SeCti°n  3'  PaCagraph B'4'  "otSng 7n  thermi
                                                                              be
                                              Civil  °r criminal  Cities  f «
     Oil and Hazardous Substance Liability
 Nothing in this permit  shall be construed  to  preclude the institution  of  any
 legal action or  relieve the permittee from anv  responsibilities,  liabiliti^
 ?h ^t    S t0 WhlCh thS P*™"66  is or «*Y  * subject unde ^ Sect ^Sn  311 of
 7.   State Laws
 Nbthing in this  permit  shall be  construed to preclude the  institution  of  any
 legal  action or  relieve  the  permittee from any  responsibilities,  liabilities
nn                         PUrSUant t0  any Applicable  State  law or
under authority preserved by Section  510 of the Act.

8.  Property Rights

The issuance  of this  permit does not  convey  any property rights of any  sort
or  any exclusive  privileges,  nor does it  authorize any  injury  to  private
property or any invasion of personal rights,  nor any  infringement  of  Federal
State or local  laws or regulations.

9-  Oishore or Offshore Construction

This permit  does not authorize or approve  the construction  of any onshore  or
offshore physical  structures or facilities  or the undertaking  of  any work  in
any waters of the United States  (including wetlands).

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                                                            Part II
                                                            Page II-3
  10. Severability
 The  provisions of  this permit  are severable, and  if any  provision of  this
 permit,  or   the   application  of  any  provision   of  this'  permit  to   any
 circumstance,  is  held  invalid,  the  application of such provision  to other
 circumstances, and the remainder of this permit, shall not be affected thereby.

 11. Duty to Provide Information

 The  permittee  shall  furnish  to  the  Permit  Issuing  Authority,   within  a
 reasonable  time,   any  information which  the  Permit  Issuing  Authority   may
 revest  to  determine  whether   cause   exists  for   modifying,   revoking   and
 reissuing,  or  terminating this  permit  or  to determine  compliance  with  this
 permit.  The permittee shall also  furnish to  the  Permit Issuing  Authority  upon
 request, copies of records required to be kept by this permit.


 SECTION B.   OPERATION AMD MAINTENANCE OF POLLUTION CONTROLS

 1.  Proper Operation and Maintenance

 The permittee shall at all times properly operate and  maintain  all facilities
 and systems of treatment and control  (and  related  appurtenances)  which  are
 installed or used by the permittee to  achieve compliance with  the conditions
 of  tnis  permit.   Proper operation and maintenance  also  includes   adequate
 laboratory   controls  and  appropriate   quality  assurance  procedures.    This
 provision requires  the operation of back-up or auxiliary facilities or similar
 systems   which  are  installed  by  a  permittee  only  when  the   operation  is
 necessary to achieve compliance with the  conditions of the permit.

 2.  Need  to Halt or Reduce not a  Defense

 It  shall not be a defense for  a  permittee  in an enforcement  action that  it
would have been necessary to halt or reduce  the permitted activity in order  to
maintain compliance with the condition of this permit.

 3.  Bypass of Treatment Facilities

    a.   Definitions

    (1)  "Bypass9 means  the intentional diversion of waste streams  from  any
         portion  of  a  treatment  facility,   which   is  not  a  designed   or
         established operating mode for the facility.

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                                                       Part II
                                                       Page II-4
 (2>  nf^!r!  p*operty   dama9e"   means  substantial  physical  daraqe  ^o
     K^I y'      9e t0  the treatment  facilities which  causes  then *o
     r^s2^retn^rt   '  °r   sabstantial  and  permanent  loss  of  natural
     a bypass   Severe^ reas°nabdly ** expected to occur in the absence of
b.   Notice
          ^H JS ! d bypass-   If the Permittee  knows in advance  of the
          iSl i.    S*1*33' lfc Sha11  SUbmit  Prior  notice'  ^ possible at
          least ten  days,  before  the  date of the  bypass;   including  *n
          evaluation of  the anticipated quality and effSTof the
                                     Permittee  shall submit  notice  of an
c.   Prohibition of bypass.


     (1)       SS "  Prohibited  and
          ^SS  " Proibited and  t^  Permit Issuing Authority  may  take
         enforcement action against a permittee for bypass, unless:

         (a)  The  bypass  was   unavoidable   to   prevent   loss  of  life
              personal injury, or severe property damage;

         (b)  There were  no  feasible  alternatives to  the bypass  (e q
              maintenance of sufficient reserve holding capacity,  the use
              ZLSO?1**!  tlea?"nt facilities<  retention of  untreated
              wastes,  waste  hauling, maintenance  of a  sufficient spare
              parts inventory, maintenance of an emergency power  supoly,
              or maintenance during normal periods of equipment  downSrri
              etc.).   This condition is not satisfied if adequate  back-up
              equipment  should  have been  installed  in  the  exercise  of
              reasonable  engineering  judgment to prevent  a bypass which
              occurred during  normal periods of  equipment  downtime  or
              preventive maintenance; and

         (c)   The permittee  submitted notices  as required under  Paragraph
              b.  of this section.
   (2)  H? **!!*}* JO*?9 *"tb°rity may,  within its authority, approve
        an anticipated bypass,  after considering its adverse effects,  if
        the  Permit Issuing  Authority determines  that it  will  meet the
        three conditions listed above in Paragraph c.(l) of this section.

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                                                           Part II
                                                           Page II-5
 4.  Upsets

    "Upset" means  an exceptional incident in which there  is  unintentional  and
    temporary  noncompliance  with technology-based permit  effluent  limitations
    because  of factors  beyond the  reasonable  control of the permittee.   An
    upset does not include  noncompliance  to the extent caused by  operational
    error/  improperly  designed  treatment  facilities,  inadequate  treatment
    facilities,  lack  of  preventive  maintenance,  or  careless  or  improper
    operation.   An  upset constitutes an affirmative  defense  to an  action
    brought for non-compliance with  such  technology-based  permit  limitation if
    the  requirements  of  40  CFR  122.41(n)(3)  are  met.   (Note  that  this
    provision  does not apply to water quality-based requirements.)

5.  Removed Substances

    This  permit  does  not  authorize  discharge  of  solids,  sludge,  filter
    backwash,  or  other  pollutants   removed  in  the  course  of  wastewater
    t reatment.
SECTION C. INSPECTION AND ENTRY.

The  permittee  shall  allow  the  Permit  Issuing  Authority,  or  an authorized
representative,  upon  the presentation of credentials  and other  documents as
may be required by law, to:'

    a.   Enter  upon the  permittee's  premises where  a regulated  facility or
         activity is located or  conducted, or where records must be kept under
         the conditions of this permit;

    b.   Ifeve access  to and copy,  at reasonable times,  any records that  must
         be kept under the conditions  of  this  permit; and

    c.   Inspect  at  reasonable  time any   facilities,  equipment  (including
         monitoring and control  equipment),  practices,  or operations regulated
         or required under this permit; and

    d.   Sample  or  monitor at reasonable times,  for the  purposes of  assuring
         permit  compliance or  as otherwise authorized  by the Clean Water  Act,
         any substances or parameters  at  any  location.

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                        Part: II
                        Paae II-6
                                       *"  in
                                       ~
  SECTION D.  REPORTING REQUIREMENTS

  1.  Change in Discharge

  The permittee  shall  give notice  to the  Permit  Issuing Authority as  soon  as
  possible of  any planned  physical alterations or  additions to  the  n^nrd^ed
  facility.   Notice  is  required  only  when  the  alteration  or addition
  change  the method of  disposal.                                  <««ir._ >n

  2.   Anticipated Noncompliance

  The  permittee shall give advance notice to the Permit Issuing Authority o'
  planned  change  in  the  permitted facility  or activity which may  r<--ult
  noncompliance  with  permit requirements.   Any  maintenance  of facilitie^" w^-h
  might  necessitate unavoidable  interruption of operation,  shall  be  sc^u^ed
  during noncritical water quality periods.                               """ ~

  3.   Transfer of Ownership or Control

  A permit may be automatically transferred to another party if:

     a.   The  permittee  notifies  the Permit  Issuing  Authority of  the proposed
          transfer at least Sundays in advance of the proposed transfer date;

     b.   The notice includes a  written agreement  between the  existing  *nd new
          permittee  containing   a  specific   date   for  transfer  of   penut
          responsibility, coverage, and liability between them; and

     c.   The  Permit  Issuing  Authority does  not  notify  the  existing  permittee
          of his or her  intent to modify  or revoke and reissue the  permit    If
          this  notice  is not received,  the transfer  is  effective on th/datp
          specified in the agreement mentioned in paragraph  b.


 4.   Twenty-Four Hour Reporting

 The permittee  shall orally report  any noncompliance which may endanger health
 or  the environment within  24 hours from the time  the permittee  becomes  aware
 of  the circumstances.   A written  submission shall also be provided within  5
 days  of  the  time the  permittee  becomes  aware  of  the  circumstances   The
 written  submission shall  contain a  description  of the  noncompliance  and  its
 cause,  an  estimate  of  the volume  discharged  and  the  name  of   the  receiving
 stream,  the period of  noncompliance, including exact  dates and  times; and  if
 the noncompliance has  not been corrected,  the  anticipated  time it  is »xpected
 to  continue,  and steps  taken  or  planned  to  reduce, eliminate, and  prevent
 reoccurrence of the noncompliance.  The  Permit Issuing Authority may vecbally
waive  the written  report, on a  case-by-case  basis,  when  the  oral  reco-t  is
made.
A-

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                                                           Part  II
                                                           Page  I1-7


 The following violations shall be included in the 24 hour report:

     a.   An unanticipated bypass which results in a  discharge to waters of the
         U.S.

     b.   Any upset which results in a discharge to waters of  the U.S.


 5.   Other Noncompliance

 The  permittee  shall report in  narrative  form,  all  instances of noncompliance
 not  previously reported under  Section D,  Paragraphs D-2 and D-4.  The  reports
 shall contain the information listed in Paragraph D-4.


 6.   Duty to Reapply

 If the permittee wishes to  continue  an activity  regulated by this  permit  after
 the  expiration date of this permit,  the permittee must apply for and obtain  a
 new  permit.  The application  should be submitted at least 180  days  before the
 expiration  date of this   permit.   The  Permit   Issuing Authority  may  grant
 permission  to  submit an  application  less  than  180 days in  advance  but not
 later than the permit expiration date.
                            •
Where EPA  is the  Permit  Issuing Authority,  the terms and condition^  of this
permit are automatically continued in accordance with 40 CFR 122.6,  only  where
 the  permittee  has  submitted a timely and  complete application for a  renewal
permit and  the Permit  Issuing  Authority is unable through no  fault  of the
permittee to issue a new permit before the expiration date.


 7.  Signatory Requirements

All  applications,   reports,  or  information  submitted to the  Permit  Issuing
Authority shall be signed and certified.

    a.   All permit applications shall be signed as follows:

         (1)  For a corporation:  by a responsible  corporate officer.   For  the
              purpose of  this  Section, a responsible corporate officer  means:
              (1)  a president,  secretary, treasurer or  vice president of  the
              corporation in  charge of a principal business function, or  any
              other person  who  performs  similar policy -  or  decision-making
              functions for the corporation,  or  (2)  the  manager of or.e  or more
              manufacturing production or operating  facilities employing more
              than   250  persons  or  having gross annual  sales  or  expenditures
              exceeding  $25 million  (in second quarter  1980  dollars),  if
              authority to  sign documents  has  been assigned or  de] gated  to
              the manager in accordance with corporate procedures.
                                A-u

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                                                 Part  II
                                                 Page  II-8
(2)
           For a partnership  or  sole proprietorship:   by a general  partner
           or the proprietor,  respectively;  or

      (3)  For a municipality, State,  Federal,  or  other public agency   by
           either a principal  executive officer  or  ranking  elected  official!

 b.    All reports required by the permit and other information  requested  by
      the Permit  Issuing Authority shall be  signed by  a  person  described
      above  or  by  a  duly authorized  representative  of  that  person   A
      person is  a duly authorized representative only if:

      (1)  Ihe authorization is made in writing  by  a person described above;

      (2)  The authorization  specifies  either an  individual  or a position
           having responsibility  for the overall operation  of the  regulated
           facility  or  activity, such  as  the  position of  plant manager
           operator  of a well or  a  well field,  superintendent, position  of
           equivalent  responsibility,  or  an individual  or  position havinq
          overall   responsibility   for  environmental  matters   for   the
          company.   (A duly authorized representative  may  thus be either a
          named  individual or any individual  occupying a named position.);
          and

      (3)  The  written  authorization  is  submitted to the  Permit  Issuinq
          Authority.       •                                               *

c.   Certification.   Any person  signing a document under paragraphs (a) or
      (b) of this section shall make the following certification:

          "I  certify  under  penalty  of  law  that  this document  and all
          attachments  were prepared under  my direction or  supervision  in
          accordance  with  a  system  designed  to assure  that  qualified
          personnel   properly   gather   and   evaluate   the   information
          submitted.   Based on  my  inquiry of  the person  or  persons who
          manage  the  system, or those persons directly  responsible for
          gathering the  information,  the information  submitted is,  to the
          best of ray  knowledge  and  belief, true,  accurate,  and complete
          I am  aware that  there are significant penalties  for submitting
          false   information,   including  the  possibility  of  fine   and
          imprisonment for knowing violations."

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                                                            Part II
                                                            Page II-9
 8.  Availability of Reports
 Except for data determined to  be  confidential  under  40 CFR Part 2,  all  reports
 prepared  in  accordance with the  terms  of this permit  shall  be available  for
 public inspection at the offices  of  the Permit Issuing Authority.   As required
 by  the Act,  permit  applications,  permits  and  effluent data  shall  not  be
 considered confidential.


 9.   Penalties for FalaJ' i<..aL .on__ot reports

 The Clean Water Act  provides  that  any person who  knowingly makes any  false
 material   statement,  representation,  or  certification  in any record or  other
 document  submitted or  required to be maintained  under this  permit,  including
 monitoring reports or  reports of  compliance or noncompliance, or who knowingly
 falsifies, tampers with, or renders  inaccurate any monitoring device or method
 required  to be maintained  under the Clean Water  Act,  shall,  upon  conviction,
 be  punished by a fine  of not more than  $10,000 or by imprisonment  for not more
 than 2 years,  or by both.


 SECTION E. DEFINITIONS

 1.   Permit Issuing Authority *

 The  Regional Administrator  of  EPA Region IV  or  his designee, unless  at  some
 time  in the future  the State  receives  the authority  to  administer the  NPDES
 program and assumes jurisdiction  over the permit; at which time,  the Director
 of the  State program  receiving  authorization becomes  the issuing authority.

 2.  Act

 "Act"  means the  Clean Water Act   (formerly referred to  as  the Federal  Water
 Pollution  Control Act)  Public  Law 92-500,  as  amended by  Public   Law  95-217,
 Public  Law 95-576 and Public Law 100-4,  33 U.S.C.  1251  et  seq.

 3.  Calendar Day

A calendar  day is  defined  as the  period  from  midnight of  one day  until
midnight   of  the  next day.    However,  for   purposes of  this  permit,  any
consecutive 24-hour  period  that reasonably represents  the calendar  day may be
used for sampling.
                                 A

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                                               Page III-l
                                               Permit No. FL0041173
                                Part III

Other Requirements

A.  Reporting of Monitoring Results

Monitoring results obtained for each calendar month shall be
summarized and reported on a Discharge Monitoring Report (DMR) Form
(EPA No. 3320-1).  These forms shall be submitted after each calendar
quarter and postmarked no later than the 28th day of the month
following the completed calendar quarter.  (For example, data for
January-March shall be submitted by April 28.)  Calendar quarters are
January-March, April-June, July-September, and October-December.
Signed copies of these, and all other reports required by Section D
of Part II, Reporting Requirements, shall be submitted to the Permit
Issuing Authority at the following address:

                    Environmental Protection Agency
                    Region IV
                    Enforcement Section
                    Water Permits and Enforcement Branch
                    Water Management Division
                    345 Courtland Street, N.E.
                    Atlanta, GA  30365

If no discharge occurs during the reporting period, sampling
requirements of this permit do not apply.  The statement "No
Discharge" shall be written on the DMR form.   If, during the term of
this permit, the facility ceases discharge to surface waters, the
Permit Issuing Authority and the State shall be notified immediately
upon cessation of discharge.  This notification shall be in writing.

B.  Reopener Clause

This permit shall be modified, or alternatively, revoked and reissued
to comply with any applicable effluent standard or limitation, or
sludge disposal requirement issued or approved under Sections
301(b)(2)(c) and (D), the effluent standard or limitation,  of sludge
disposal requirement so issued or approved:

    (1)   Contains different conditions or is otherwise more stringent
         that any condition in the permit; or
    (2)   Controls any pollutant , or disposal method not in the
         permit.

The permit as modified or reissued under this paragraph shall contain
any other requirements of the Act then applicable.

C.  Polychlorinated Biphenyl Compounds

There shall be no discharge of polychlorinated biphenyl compounds,
such as  those commonly used for transformer fluid.

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                                               Page III-2
                                               Permit No.
FL0041173
D.  Erodible Material Storage
The permittee shall not store coal, soil, nor other similar erodible
materials in a manner in which runoff is uncontrolled, nor.conduct
construction activities in a manner which produces uncontrolled
runoff unless such uncontrolled runoff has been specifically approved
by the Director.  "Uncontrolled" shall mean without sedimentation
basin or other controls approved by the Director.  This permit may be
modified to include limitations for the discharge from such
facilities, when installed.

E.  Detection Limits

If the results for a given sample analysis are such that any
parameter is not detected at or above the minimum level for the test
method used, a value of zero will be used for that sample, and the
permittee shall report "NODI=B" on the Discharge Monitoring Report
(DMR) Form  (EPA No. 3320-1).  For eacfci quantitative sample value that
is not detectable, the test method, as well as the  minimum level for
the analytical test method selected, shall be attached to and
submitted with the DMR.  The permittee shall then be considered to be
in compliance with the appropriate effluent reporting requirement.

F.  Combined Waste Streams

In accordance with 40 CFR Section 423.12(12), in the event that waste
streams from various sources are combined for treatment or discharge,
the quantity of each pollutant or pollutant property attributable to
each controlled waste source shall not exceed the specified
limitation for that waste source.

G.  Unauthorized Discharges

Except as specifically permitted for Outfall 003 and 008, there shall
be no point source discharge of any wastes to waters of the United
States, or to any waste stream which enters such waters.

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                                                       Page IV-1
                                                       Permit No. FLOO


                                  PART IV
         BEST MANAGEMENT PRACTICES/POLLUTION PREVENTION CONDITIONS


A.   GENERAL CONDITIONS

     In accordance with Section 304(e) and 402(a)(2) of the Clean Water Act
     (CWA) as amended, 33 U.S.C. §§ 1251 et seq., and the Pollution
     Prevention Act of 1990, 42 U.S.C. SS 13101-13109, the permittee must
     develop and implement a plan for utilizing practices incorporating
     pollution prevention measures.  References to be considered in
     developing the plan are "Criteria and Standards for Best Management
     Practices Authorized Under Section 304(e) of the Act," found at 40 CFR
     125, Subpart K and the Waste Minimization Opportunity Assessment
     Manual, EPA/625/7-88/003.

      1.  Definitions

          a.   The term "pollutants" refers to conventional,
               non-conventional and toxic pollutants.
          b.   Conventional pollutants are: biochemical oxygen demand
               (BOD), suspended solids, pH, fecal coliform bacteria and oil
               & grease.
          c.   Non-conventional pollutants are those which are not defined
               as conventional or toxic, such as phosphorus, nitrogen or
               ammonia.
          d.   Toxic pollutants include, but are not limited to: a) any
               toxic substance listed in Section 307(a)(1) of the CWA, any
               hazardous substance listed in Section 311 of the CWA, or
               chemical listed in Section 313(c) of the Superfund
               Amendments and Reauthorization Act of 1986; and b) any
               substance (that is not also a conventional or
               non-conventional pollutant) for which EPA has published an
               acute or chronic toxicity criterion.
          e.   "Pollution prevention" and "waste minimisation" refer to the
               first two categories of EPA's preferred hazardous waste
               management strategy: first, source reduction and then,
               recycling»
          f.   "Recycle/Reuse" is defined as the the minimization of waste
               generation by recovering and reprocessing usable products
               that might otherwise become waste; or the reuse or
               reprocessing of usable waste products in place of the
               original  stock, or for other purposes such as material
               recovery, material regeneration or energy production.
          g.   "Source reduction" means any practice which: i) reduces the
               amount of any pollutant entering a waste stream or otherwise
               released  into the environment  (including fugitive emissions)
               prior to  recycling, treatment or disposal; and ii) reduces
               the hazards to public health and the environment associated
               with the  release of such pollutant.  The term includes
                                    A -n

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                                                 Page IV-2
                                                 Permit No. FLOO
         equipment or technology modifications, process or procedure
         modifications, reformulation or redesign of products,
         substitution of raw materials, and improvements in
         housekeeping, maintenance, training, or inventory control.
         It does not include any practice which alters the physical,
         chemical, or biological characteristics or the volume of a
         pollutant through a process or activity which itself is not
         integral to, or previously considered necessary for, the
         production of a product or the providing of a service.
     h.  "BMP3" means a Best Management Plan incorporating the
         requirements of 40 CFR S 125, Subpart K, plus pollution
         prevention techniques associated with a Waste Minimization
         Assessment.
     i.  "Waste Minimization Assessment" means a systematic planned
         procedure with the objective of identifying ways to reduce
         or eliminate waste.

2«  Best Management Practices/Pollution Prevention Plan

    The permittee shall develop and implement a BMP3 plan for th£
    facility which is the source of wastewater and storm water
    discharges covered by this permit.  The plan shall be directed
    toward reducing those pollutants of concern which discharge to
    surface waters and shall be prepared in accordance with good
    engineering and good housekeeping practices.  For the purposes of
    this permit, pollutants of concern shall be limited to toxic
    pollutants, as defined above, known to the discharger.  The plan
    shall address all activities which could or do contribute these
    pollutants to the surface water discharge, including process,
    treatment, and ancillary activities.

3.  Signatory Authority & Management Responsibilities

    The BMP3 plan shall be signed in accordance with Item II.D.12.
    and shall be reviewed by the plant engineering staff and plant
    manager.  A copy of the plan shall be retained at the facility
    and shall be made available to the permit issuing authority upon
    request.

    The BMP3 plan shall contain a written statement from corporate or
    plant management indicating management's commitment to the goals
    of the BMP3 program.  Such statements shall be publicized or made
    known to all facility employees.  Management shall also provide
    training for the individuals responsible for implementing the
    BMP3 plan.
                            A-

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                                                 Page IV-3
                                                 Permit No. FLOO
4.  BMP3 Plan Requirements
    a.   name & description of facility, a map illustrating the
         location of the facility & adjacent receiving waters, and
         other maps, plot plans or drawings, as necessary;

    b.   overall objectives (both short-term and long-term) and scope
         of the plan, specific reduction goals for pollutants,
         anticipated dates of achievement of reduction, and a
         description of means for achieving each reduction goal;

    c.   a description of procedures relative to spill prevention,
         control & countermeasures and a description of measures
         employed to prevent storm water contamination;

    d.   a description of practices involving preventive maintenance,
         housekeeping, recordkeeping, inspections, and plant
         security;

    e.   the description of a waste minimization assessment performed
         in accordance with the conditions outlined in Section 5
         below, results of the assessment, and a schedule for
         implementation of specific waste reduction practices;
         5.   Waste Minimization Assessment

    A waste minimization assessment (WMA) shall be conducted for this
    facility to determine actions that could be taken to reduce waste
    loadings and chemical losses to all wastewater and/or storm water
    streams as described in Part IV.B of this permit.  It shall
    address both short-term and long-term opportunities for
    minimizing waste generation at this facility, utilizing at a
    minimum, applicable criteria selected from Part IV.B: Required
    Components of a Waste Minimization Assessment, particularly for
    high volume and/or high toxicity components of wastewater and
    storm water streams.  Initially, the WMA should focus primarily
    on actions that could be implemented quickly, thereby realizing
    tangible benefits to surface water quality.  Long term goals and
    actions pertaining to waste reduction shall include investigation
    of the feasibility of eliminating toxic chemical use, instituting
    process changes, raw material replacements, etc.

    Implementation of Results:  The permittee shall implement each
    waste reduction practice recommended by the WMA as soon as
    practicable.  Any waste reduction practices which are identified
    but will not be implemented shall be described in the required
    Pollution Prevention plan summary or proqress/update reports,
    along with the factors inhibiting their adoption.  Any waste
    reduction practices which cannot be implemented immediately shall
    be described in the Pollution Prevention plan.
                            A-fl

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                                                 Page IV-4
                                                 Permit No. FLOO

    Timeframe;  The permit issuing authority does not herein
    establish a time limit for completion of the WMA; the study may
    be conducted throughout the term of this permit.  However, a
    suggested target completion date is six months after the
    effective date of the permit, so that the WMA results and
    recommended waste reduction practices may be incorporated into
    the BMP3 plan.  Continual studies toward minimizing waste are
    encouraged.

    Practices which reduce pollutant loading in wastewater or storm
    water discharges with a consequent increase in solid hazardous
    waste generation, decrease in air quality, or adverse affect to
    groundwater shall not be considered waste reduction for the
    purposes of this assessment*


6-  Best Management Practices & Pollution Prevention Committee
    Recommended;

    A Best Management Practices Committee (Comittee) should be
    established to direct or assist in the implementation of the BMP3
    plan.  The Committee should be comprised of individuals within
    the plant organization who are responsible for developing the
    BMP 3 plan and assisting the plant manager in its implementation,
    monitoring of success, and revision.  The activities and
    responsibilities of the Committee should address all aspects of
    the facility's BMP3 plan.  The scope of responsibilities of the
    Committee should be described in the plan.
7.       Employee Training

       Employee  training  programs  shall  inform personnel at all
       levels  of  responsibility  of the components &  goals of the BMP3
       plan  and  shall describe employee  responsibilities for
       implementing the plan.  Training  shall  address topics such as
       good  housekeeping,  materials management, recordkeeping  &
       reporting,  spill prevention & response, as well as specific
       waste reduction practices to be employed.  Training should
       also  disclose how  individual employees  may contribute
       suggestions concerning the  BMP3 plan or suggestions regarding
       Pollution  Prevention.  The  plan shall identify periodic dates
       for such training.


8.       Plan Development & Implementation

       The BMP3 plan shall be developed  and implemented 6 months
       after the  effective date  of this  permit, unless any later
       dates are  specified by the  Director.  Any portion of the WMA
       which is ongoing at the time of development or implementation
       shall be described in  the plan.   Any waste reduction practice
                              A'2-O

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                                                 Page IV-5
                                                 Permit No. FLOO

      which is recommended  for  implementation over a period of  time
      shall be identified in the plan, including a schedule for its
      implementation.


9.    Submission of Plan Summary & Progress/Update Reports

      a.   Plan Summary;

           Not later than 2 years after the effective date of the
           permit, a summary of the BMP3 plan shall be developed and
           maintained at the facility and made available to the
           permit issuing authority upon request.  The summary
           should include the following: a brief description of the
           plan/ its implementation process, schedules for
           implementing identified waste reduction practices, and a
           list of all waste reduction practices being employed at
           the facility.  The results of waste minimization
           assessment studies already completed as well as any
           scheduled or ongoing WMA studies shall be discussed.
                                 *
      b.   Progress/Update Reports:

           Annually thereafter  for the duration of the permit
           progress/update reports documenting implementation of the
           plan shall be maintained at the facility and made
           available to the permit issuing authority upon request.
           The reports shall discuss whether or not implementation
           schedules were met and revise any schedules, as
           necessary.  The plan shall also be updated as necessary
           and the attainment or progress made toward specific
           pollutant reduction  targets documented.  Results of  any
           ongoing WMA studies  as well as any additional schedules
           for implementation of wast ' reduction practices shall be
           included.
                                 - -        v

      c.   A  timetable for the  various plan requirements follows:

           Timetable for BNP3 Plan Requirements*


           REQUIREMENT                 TIME FROM EFFECTIVE DATE OF
                                       THIS PERMIT


           Complete WMA                          6 months

           Develop & Implement  Plan              6 months

           Develop Plan Summary                 2 Years
                            A-21

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                                                       Page IV-6
                                                       Permit No. FLOO

                  Progress/Update  Reports               3 years, and then
                                                       annually thereafter

                  The permittee shall maintain the plan  and subsequent
                  reports at the facility  and shall make the plan available
                  to the Permit Issuing Authority upon request.

     10.    Plan Review & Modification

            If  following review by  the Director, or authorized
            representative, the BMP3 plan is determined insufficient,
            he/she may notify the permittee that the BMP3 plan does not
            meet one or more of the minimum requirements of this Part.
            Upon such notification  from the Director, or authorized
            representative, the permittee shall amend the plan and shall
            submit to the Director  a written certification that the
            requested changes have  been made.  Unless otherwise provided
            by  the Director, the  permittee shall have 30 days  after such
            notification to make  the changes necessary.

            The permittee shall modify .the BMP3 plan whenever  there is a
            change in design, construction, operation,  or maintenance,
            which has a significant effect on the potential for the   x
            discharge of pollutants to waters of the United States or if
            the plan proves to be ineffective in achieving the general
            objectives of reducing  pollutants in wastewater or storm  water
            discharges.  Modifications to the plan may  be reviewed by EPA
            in  the same manner as described above.

     11.    SPECIFIC CONDITIONS

            These conditions will be incorporated according to Best
            Professional Judgement  (BPJ)  for specific areas in which
            standard conditions may not address.


B.   REQUIRED COMPONENTS OF A WASTE MINIMIZATION ASSESSMENT

     1.   Plant Water Balance

          The WMA shall include an overall plant water balance, as well as
          internal water balances, as necessary.   This information shall be
          used to determine  any opportunities for water conservation or
          reuse/recycling and to determine if and where leakages might
          occur.

     2.   Material and  Risk  Assessment

          A materials  & risk assessment shall be developed and shall
          include the  following:
                                    A-22

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                                                 Page IV-7
                                                 Permit No. FLOO

    a.    identification of the types & quantities of materials used
         or manufactured (including by-products produced) at the
         facility;

    b.    identification of the location & types of materials
         management activities which occur at the facility;

    c.    an evaluation of the following aspects of materials
         compatibility: containment & storage practices for
         chemicals, container compatibility, chemical mixing
         procedures; potential mixing or compatibility problems; and
         specific prohibitions regarding mixing of chemicals;

    d.    technical information on human health and ecological effects
         of toxic or hazardous chemicals presently used or
         manufactured (including by-products produced) or planned for
         future use or production;

    e.    analyses of chemical use & waste generation, including
         overall plant material balances and as necessary, internal
         process balances, for all pollutants.  (When actual
         measurements of the quantity of a chemical entering a
         wastewater or storm water stream are not readily available,
         reasonable estimates should be made based on best
         engineering judgment.)  The analyses shall address reasons
         for using particular chemicals, and measures or estimates of
         the actual and potential chemical discharges via wastewater,
         wastewater sludge, storm water, air, solid waste or
         hazardous waste media.

3.  Pollutant Reduction Methods

    The WMA shall include, at a minimum, the following means of
    reducing pollutant discharges in wastewater streams or of
    otherwise minimizing wastes:

    a.    process related source reduction measures, including any or
         all of the following, as appropriate:

         1)   production process changes;
         2)   improved process controls;
         3)   reduction of off-spec materials;
         4)   reduction in use of toxic or hazardous materials;
         5)   chemical modifications and/or material purification;
         6)   chemical substitution employing non-toxic or less toxic
              alternatives; and
         7)   equipment upgrades or modifications or changes in
              equipment use.
                          A -2.3

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                                                 Page IV-8
                                                 Permit No. FLOO

    b.   housekeeping/operational changes, including waste stream
         segregation, inventory control, spill & leak prevention,
         equipment maintenance; and employee training in areas of
         pollution prevention, good housekeeping, and spill
         prevention & response;

    c.   in-process recycling, on-site recycling and/or off-site
         recycling of materials;

    d.   following all source reduction & recycling practices,
         wastewater treatment process changes, including the use of
         new or improved treatment methods, such that treatment
         by-products are less toxic to aquatic or human life; and

    e.   other means as agreed upon by the permit issuing authority
         and the permittee.


4.  Storm Water Evaluation

    For storm water discharges and instances where storm water enters
    the wastewater treatment/disposal system or is otherwise
    commingled with wastewater, the WMA shall evaluate the following
    potential sources of storm water contamination, at a minimum:

    a.   loading, unloading and transfer areas for dry bulk materials
         or liquids;

    b.   outdoor storage of raw materials or products;

    c.   outdoor manufacturing or processing activities;

    d.   dust or particulate generating processes;

    e.   on-site waste and/or sludge disposal practices.

    The likelihood of storm water contact in these areas and the
    potential for spills from these areas shall be considered in the
    evaluation.  The history of significant leaks or spills of toxic
    or hazardous pollutants shall also be considered.
    Recommendations for changes to current practices which would
    reduce the potential for storm water contamination from these
    areas shall be made, as necessary.

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w,
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                 REGION IV            jyj_ QV 1993

                                  DRAFT
                           345 COURTLAND STREET. N.E.
                            ATLANTA. GEORGIA 3O365
                          Statement of Basis

                           Application for
            National Pollutant Discharge Elimination System
                 Permit to Discharge to Waters of the
                            United States


NPDES No.:         FL0004117

Facility Name:      Cedar Bay Cogeneration Facility

Location:          9469  Eastport Road
                   Duval County
                   Jacksonville, Florida  32218

Receiving Stream:   Broward River (freshwater)

Classification:    Class III Waters

Use Designation:    Recreation, Propagation and Maintenance of a
                   Healthy, Well-Balanced Population of Fish and
                   Wildlife

Permit Writer:  Karrie-Jo Shell


Facility Description:

This facility is  a coal-fired, steam electric generating  facility
(SIC Code 4911).   This cogeneration facility is designed  to provide
up to 380,000 pounds per hour of process steam to an adjacent paper
mill, as well as  250 megawatts (net) of electricity for revenue.

Wastewaters consist of storm water runoff from the material storage
area (includes coal, ash,  and limestone storage and handling areas)
and runoff from the yard area (includes areas around the  power block
and cooling tower).   Wastewaters are treated by sedimentation in two
onsite retention  ponds.

Bases for Permit  Conditions:

                             Outfall 003
           (Ground Runoff  and, Roof & Yard Drain Discharges)

Flow and Total Suspended Solids;  Monitoring and reporting
requirements are  based on  best professional judgement (BPJ), and are
consistent with Section  308(a) of the Clean Water Act of  1987 (CWA).

pH: Based on Florida Administrative Code (FAC) Section 17-302.560(32)
(dated 1/5/93).
                               A-25
                                                          Printed on Recycled Paper

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                                   -2-
                                             122-44'd>
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            APPENDIX B

         STATE OF FLORIDA'S
FINAL ORDER APPROVING MODIFICATION
   OF CERTIFICATION SETTLEMENT
     AGREEMENT AND CONDITIONS
         OF CERTIFICATION

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                 BEFORE THE  GOVERNOR AND CABINET
                         STATE OF FLORIDA
                    SITTING AS THE SITING BOARD
IN RE:
POWER PLANT SITE CERTIFICATION
OF CEDAR BAY COGENERATION
PROJECT, PA-88-24
DOAH Case No. 88-5740
OGC Case No. 88-1089
       FINAL ORDER APPROVING MODIFICATION OF CERTIFICATION

    On June 17,  1992, the Siting Board entered an Order
Instituting Modification Proceedings with respect to the power
plant site certification issued February 18, 1991, to AES Cedar
Bay, Inc., and Seminole Kraft Corporation for the Cedar Bay
Cogeneration Project in Jacksonville.  The certification
modification proceedings were docketed as DOAH Case No. 88-5740.
                                *
On or about April 13, 1993, all parties to the modification
proceedings before DOAH executed a Settlement Stipulation dated
April 12, 1993,  which resolved all disputed issues of fact and
law among the parties.  On April 14, 1993, a Joint Agreed Motion
to Relinquish Jurisdiction based upon the Settlement Stipulation
was filed by the Department on behalf of all parties.  On April
28, 1993, the assigned DOAH Hearing Officer, Robert T. Benton II,
entered an order relinquishing jurisdiction of the proceeding to
the Board for the purpose of taking final agency action in the
matter.
    The Siting Board, having reviewed the terms of the Settlement
Stipulation and  otherwise having been fully advised as to this
matter, concludes that the Stipulation effects an appropriate
resolution of the controversy over the site certification for the
                           e>

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operation vill comply vith toe non.proceaural ^^
   cedar Bay generation Project.   The Board believes that this
   resolution is consistent vith the public  interest and vith the
   intent of the Board as expressed  in  its Order of June „. 1992
   The revised Conditions of Certification agreed to
   -attached as Appendix  A iffiplenent ^ ^
                to the project and assure that construction and
                l comply vi
  agencies of jurisdiction.
      Accordingly,  the Board ORDERS:

  ;;-Jhvert:fioation for the ceaa
  a* 24. .ssued re.ruary 18, 1991, is HODIFIED.
  certlflcation contained in Appendix A shaZl henceforth apply to
  govern construction  and operation  of the Cedar Bay Cogeneration
  Pro3ect „  accordance vith Section  <03.5ll, Florida stafcutes
  (Supp.  1992).
  2-  The certification is further MODIFIED to reflect that the
 n-. Of certificate holder AES Cedar Bav,  Inc. has been changed
 to cedar Bay Cogeneration,  Inc.

               to ttis order has toe right to
   9    bv    .pursuant to section
 »92,  by flllng . Notioe of Appe
 Florida Rules of Appellate  Procedure, vith the cler* of the
 Department of Environmental Regulation and office of General
 counsel, 2600 Blair stone Road, Tallahassee, rlorida  32399-2400;
 and by filing . copy 0£ the Notice of Appeai< accompaniea
the applicable filing fees,  vith the appropriate District  Court
°* Appeal.  The Notice of Appeal nust be  filed vithin 30 days
                                2
                              6-2

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from the date this Order is filed with the Clerk of the
Department of Environmental Regulation.
    DONE AND ORDERED this JJ^ day of May, 1993,  in Tallahassee,
Florida, pursuant to the vote of the Governor and Cabinet,
sitting as the Siting Board, at the duly constituted Cabinet
meeting on May 11, 1993.

                                    BY THE GOVERNOR AND CABINET,
                                    SITTING AS THE^SITING BOARD
                                           Chiles, ^Governor
                           (3-3

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                       CERTIFICATE OF SERVTPB
     I DO HEREBY CERTIFY that a true and correct copy of the
                                     u-s-
 Gary Sams,  Esq.
 Hopping Boyd Green & Sams
 P O  Box 6526
 Tallahassee FL  32314
 Terry Cole,  Esq.
 Scott Shirley,  Esq.
 Oertel Hoffman  Fernandez & Cole
 P O Box 6507
 Tallahassee  FL   32314-6507
                                   Gregory K. Radlinski, Esq.
                                   City of Jacksonville
                                   600 City Hall
                                   220 E Bay St
                                   Jacksonville FL  32202

                                   M.B. Adelson, IV
                                   Assistant General Counsel
                                   Douglas Bldg MS-35
                                   3900 Commonwealth Blvd
                                   Tallahassee FL  32399-3000
Jim Antista,  General Counsel
Florida Game  &  Fresh Water
  Fish Commission
620 s Meridian  Rd
Tallahassee FL   32399-1600
Lucky Osho, Esq.
Department of Community Affairs
2740 Centerview Dr
Tallahassee FL  32399-2100

Earl M. Barker, Esq.
Slott & Barker
334 East Duval St
Jacksonville, FL  32302

Lawrence N. Curt in, Esq.
Holland & Knight
P O Drawer 810
Tallahassee FL  32302
this
                                   Rob Vandiver,  General Counsel
                                   Mike Palecki,  Chief
                                   Bureau of Electric &  Gas
                                   Florida Public Service Cpmms
                                   101 E Gaines St
                                   Tallahassee FL  32399-0850

                                   James A.  Heard,  Esq.
                                   2902 Independent Sq
                                   Jacksonville FL  32202
                                   Lisa B. Cooper, Esq.
                                   Margol  & Pennington
                                   76 Laura St
                                   Jacksonville FL  32202

                                   Nancy B. Barnard, Esq.
                                   St Johns River Water
                                    Management District
                                   P 0 Box 1429
                                   Palatka FL  32178-1429
            day of May, 1993.
                                  STATE OF FLORIDA DEPARTMENT
                                  OF ENVIRONMENTAL REGULATION
                                  RICHARD T. DONELAN,
                                  Assistant General Counsel

                                  Twin Towers Office Bldg
                                  2600 Blair Stone Rd
                                  Tallahassee FL  32399-2400
                                  Telephone:  904/488-9730

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                        STATE OF FLORIDA
               DIVISION OF ADMINISTRATIVE HEARINGS
AES CEDAR BAY,INC., and            )
SEMINOLE KRAFT CORPORATION,        )

               Petitioners,        )

VS.                                )    DOAH CASE NO.  88-5740

STATE OF FLORIDA DEPARTMENT OF     )
ENVIRONMENTAL REGULATION,          )

               Respondent,         )

and                                )

CITY OF JACKSONVILLE,              )
DEPARTMENT OF COMMUNITY AFFAIRS,   )
PUBLIC SERVICE COMMISSION, ST.     )
JOHNS RIVER WATER MANAGEMENT       )
DISTRICT, JACKSONVILLE ELECTRIC    )
AUTHORITY, CHARLES W. BOSTWICK,    )
WILLIAM C. BOSTWICK, BARNETT       )
BANKS TRUST COMPANY, N.A., IMESON  )
INTERNATIONAL PARK, INC., and      )
INDUSTRIAL PARK DEVELOPMENT        )
CORPORATION, CITIZENS COMMITTEE,   )
INC., SIERRA CLUB, FLORIDA         )
AUDUBON SOCIETY, THE DUVAL         )
AUDUBON SOCIETY, INC., and         )
STAFFORD CAMPBELL,                 )

               Intervenors.        )
                      SETTLEMENT  STIPULATION


     The  parties  in this  and  related proceedings,  Cedar  Bay

Cogeneration, Inc. ("CBC")  (formerly known as AES Cedar Bay, Inc.),

Seminole  Kraft  Corporation  ("SK"),  the Florida  Department  of

Environmental Regulation ("DER"), St. Johns River Water Management

District ("SJRWMD"),  City of Jacksonville, the Citizens' Committee,

Inc. (including all of its  members, who  are listed on Attachment A
                             6-5

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hereto), William C. Bostwick, Sierra Club, Florida Audubon Society,
The  Duval  Audubon  Society,   Inc.,  and  Stafford  Campbell,  as
indicated below  by their signatures or the signatures  of  their
counsel or representatives (collectively "the Parties"), enter into
the  following  settlement stipulation and agreement (Agreement),
which shall  be  binding on themselves and  their members, principals,
successors  and assigns.   Persons  signing on behalf of  a group,
organization,  or  legal entity represent   that  they  have  all
necessary power and authority to execute this agreement and to bind
said group,  organization, or legal entity and its members.
A. Purposes
     1.   The  intent of  this Agreement  is  to resolve  fully and
finally, and with prejudice,  all disputes, issues or other matters
arising  in  the  above-styled  proceeding  and  in  all  related
permitting proceedings or appeals at the federal,  state, regional
and local levels arising out of, or related to, the certification
of,  the  petition  for  modification of  certification of, or the
permitting  of, the  Cedar  Bay Cogeneration  Project ("CBCP"  or
"Project") and its construction and operation in a manner binding
on the  parties to this  Agreement.   This Agreement  resolves all
issues  which  were  raised  or  could  have  been raised  in  this
proceeding or  any other  proceeding, including  but  not limited to
the issue of use  of  natural gas in the Project or the  Project's
satisfaction of federal, state, regional and  local environmental or
other regulations.   The parties will not seek administrative or
judicial review,  or seek revocation of, any certification or permit

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for  the Project  which  is  consistent  with  the terms  of  this
Agreement.   This Agreement neither waives  nor expands  the rights
available to any Party under existing law  to seek enforcement or
any other remedy for violation of this Agreement, the conditions of
certification, or any state or federal permit for facts occurring
after the date of this Agreement.
     2.  Each Party hereby requests,  intending to be bound by its
individual execution  of this Agreement,  that the  Florida Power
Plant Siting  Board  (Siting Board) enter a  Final  Order Approving
Modification of Site Certification that contains the Conditions of
Certification attached hereto as Attachment B and the provisions of
this Agreement contained in Paragraphs 3 through 6 inclusive.  All
other provisions of this Agreement which  are not included in the
modified  certification   or  other   related  permit   shall  be
independently binding  on the parties  hereto.   Furthermore, the
parties  agree that the  findings implicit  and explicit  in this
document  establish that,  if  operated  in  compliance with the
certification and applicable  permits, the CBGP as now proposed plus
the package boilers now proposed by SKC fully satisfy the Florida
Electrical Power Plant Siting Act, all applicable federal, state,
regional and  local  environmental requirements,  and  the Siting
Board's Order Initiating Modification Proceedings, dated June 17,
1992, and are  associated with, n[o]n balance,** fewer "environmental
impacts" than are  associated  with  the  SKC  recycling operation
without the CBCP as now proposed.

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B.  Conditions of Certification

     3.  A revised Condition of Certification No. XXVIII shall be

included  in  the Conditions  of  Certification  as  contained  in

Attachment C hereto.

     4.   An additional condition of  certification  No.  II.A.B.C.

shall be included in the Conditions of Certification,  as follows:

          Compliance tests  shall be performed for  mercury (Hg),
     beryllium  (Be), and lead  (Pb)  until three consecutive tests
     (including, if successful,  the initial  compliance  test) are
     within  the annual  emission limits  specified in  Condition
     II.A.3. above.  Such tests shall occur,  as necessary, in the
     first, fifth and  tenth years and additional successive five
     year intervals following commercial  operation of the Project.

     5.  Revised Conditions  of Certification No. II.A.6 and II.A.9.

to address the use of Continuous Emissions Monitors for determining

compliance  with emissions  limits  for  sulfur dioxide,  nitrogen

oxides,  carbon  monoxide  and  opacity  shall  be  included  in the

Conditions of Certification, as follows:

          6.   Compliance  with  the  emission  limits  shall  be
     determined by EPA reference method tests included in the July
     l,  1992  version  of  40 CFR Parts.^60. and 61, Rule  17-297,
     F.A.C., and listed in  Condition No.  II.A.8 of this permit or
     by equivalent  methods  after prior written DEP approval.  In
     addition,   compliance  with  the emission  limitations  in
     Condition No. II.A.3 for CO, NO,, and SO2 and with the opacity
     requirements in Condition No.II.A.5 shall be determined with
     the Continuous Emission Monitoring Systems  (CEMs) identified
     in Condition No.  II.A.9.

          9.   CBCP shall install, certify, calibrate, operate, and
     maintain continuous emission monitoring systems for opacity,
     SO2,  NOZ,  CO,  and  02  or  C02,  pursuant  to all  applicable
     requirements  of  Rule  17-296.800,  F.A.C.,  Chapter  17-297,
     F.A.C., 40 CFR 60 Subpart A, 40 CFR 60 Subpart Da, 40 CFR 60
     Appendix B,  and  40 CFR 60 Appendix  F.  These CEMs shall be
     used to determine compliance with the emission  limitations in
     Condition No. II.A.3 for CO, NO,, and S02 and with the opacity

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     requirements in Condition No. II.A.5.  The permittee may elect
     to install,  certify, calibrate, operate,  and maintain multiple
     span continuous emission monitoring systems for sulfur dioxide
     and  nitrogen   oxides  providing   certification  tests  and
     calibrations  are performed  for  each  span.    Each of  the
     continuous emission monitoring systems for sulfur dioxide and
     nitrogen oxides shall continuously record data on a span that
     satisfies the requirements of 40 CFR 60.47a.  Any exception to
     the above must  be specifically authorized by DEP in writing
     and in accordance with state and federal regulations.

     6.  Revised Conditions of Certification II.D.  and  II.E.  to

address Seminole Kraft Corporation's annual emissions from its new

package boilers and actions to dismantle or render inoperable SK's

existing power  and bark boilers  following surrender of  the air

permits for those boilers shall be  included  in the  Conditions of

Certification as follows:

     D.   Contemporaneous Emission Reductions

          This certification and any individual air permits issued
     subsequent  to  the final  order of the  Board certifying the
     power plant site under section 403.509, F.S.,  shall require
     that the  following  Seminole  Kraft  Corporation sources  be
     permanently shut  down  and  made incapable of operation,  and
     shall turn in their operation permits to the Division of Air
     Resources Management's Bureau  of  Air Regulation, within 30
     days  of  written confirmation by DER of  the  successful
     completion  of  the  initial  compliance  tests   on  the  CBCP
     boilers:  the No. 1 PB (power-boiler)*/ the No.  2 PB, the No.
     3 PB, the  No.  1 BB  (bark boiler),  and  the  No. 2 BB.   RESD
     shall be specifically informed in writing within thirty days
     after each  individual shut  down of the above  referenced
     equipment.  Within one  year of  surrender of operating permits
     as provided above, SK shall have completed the following steps
     to ensure compliance with this condition:

          Remove all oil guns;

          Remove motors and selected conveyor parts  in wood feed
               system for bark boilers;

          Dismantle stacks;

          Disconnect boiler feedwater pumps;

          Sever fuel line connections;  and

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          Remove fan motors.

          These sources shall  not,  under  any  circumstances, be
     restarted, refurbished or  re-permitted as  new  or existing
     sources,  at the SK or  CBCP  site.

          This requirement  shall operate as a joint and  individual
     requirement to assure  common  control  for purpose of ensuring
     that all  commitments relied on  are  in fact fulfilled.

          E.    SK Steam Boiler Emissions

          1.    This certification  and any individual air permits
     issued by the Department subsequent to the final  order  of the
     Board certifying the power  plant site under  Section 403.509,
     Florida Statutes,  shall incorporate the following limitations
     on the total tonnage  of the specified criteria  pollutants
     allowed to be emitted annually by any natural gas-fired  boiler
     or combination of boilers constructed and operated by SK to
     provide up to 375,000 Ibs/hr.  of steam for use in its recycled
     paper process:
                    Tons Per Year
                    CO  553
                    NO,  310
                    S02  25, except  as provided  in E.2  below.

          2.    In the event that the ceiling for S02 is expected to
     be exceeded  due to unavailability  of natural gas caused by
     factors beyond the control of  SK, SK may notify the  Department
     that  it  must  exceed  the  ceiling  as  provided  herein; and
     emissions of S02 during the period  of such  curtailment shall
     not be counted against the yearly emissions ceiling of 25 tons
     unless administrative  proceedings result in a finding that the
     exceedance was within  Seminole  Kraft's control.  In no event
     shall the annual emissions  of S02  from  the steam boilers
     referenced above exceed a  ceiling of  41 tons per year.

          3.    The notice shall  include  a statement of reasons for
     the  request  and  supporting documentation,  and  shall be
     published by SK, without supporting documents, in a newspaper
     of general circulation in  Jacksonville as defined  in section
     403.5115(2), Florida Statutes.   The filing and publication of
     the  notice  no later  than  7  days  following the  date of
     exceedance shall  preclude  any  finding  of  violation  by DER
     until final disposition of any administrative proceedings.

C.  Other Environmental Provisions

     7.  As an incentive to achieve lower sulfur dioxide emissions

than permitted under the Conditions of Certification, CBC shall pay

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annually to the City of Jacksonville, Land Acquisition Trust Fund,
$400 for each ton of sulfur dioxide emitted in excess of 2208 tons
per calendar year from the CBCP's three circulating fluidized bed
boilers, combined,  up to the total annual permitted sulfur dioxide
emissions  for the  Project;  provided,  however,  that any  taxes,
charges or fees payable under an applicable regulatory program on
account of emissions above  2208 tons per year  but below the maximum
permitted annual emissions'shall be deducted  from the $400 per ton
payable under this provision.  The annual sulfur dioxide emissions
from the CBCP's CFB boilers for purposes of this provision shall be
determined based  on continuous  emissions monitoring data for the
calendar year.  The amount of  any such payments due for a calendar
year shall be determined by March 1st of the  following year and be
paid to the City of Jacksonville, Land Acquisition Trust Fund, by
May 1st.  Any   annual emissions of  sulfur  dioxide above 2208 TPY
but  below  the  maximum permitted  annual   emissions  shall  not
constitute a  violation of the Conditions of Certification or of
this Agreement.
     8.  As an incentive to achieve lower nitrogen oxide emissions
than permitted under the Conditions of Certification,  CBC shall pay
annually to the City of Jacksonville, Land Acquisition Trust Fund,
$200 for each ton of nitrogen oxides emitted in excess of 1948 tons
per calendar year from the CBCP's three circulating fluidized bed
boilers, combined,  up to the total annual permitted nitrogen oxide
emissions  for the  Project;  provided,  however,  that any  taxes,
charges or fees payable under an applicable regulatory program on

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account of emissions above 1948 tons per year but below the maximum
permitted annual emissions shall be deducted from the $200 per ton
payable under this provision.  The annual nitrogen oxide emissions
from the CBCP's  CFB boilers for purposes of this provision shall be
determined based on continuous emissions monitoring data  for the
calendar year.  The amount of any such payments due for a calendar
year shall be determined by March 1st of the following year and be
paid to the City of Jacksonville,  Land Acquisition Trust Fund, by
May 1st.  Any  annual emissions of nitrogen oxides above 1948 TPY
but  below  the   maximum permitted  annual  emissions  shall  not
constitute a  violation  of  the Conditions of Certification  or of
this Agreement.
     9.  CBC agrees to donate to the City of Jacksonville the sun
of  $575,000  within  30  days  after  commencement of  commercial
operation.    Of  this  sum,   $350,000  shall  be  earmarked  for
construction  of  a  new  fire  station east of the  rail  line in the
vicinity of the  intersection of Main St.  and Busch Dr. to improve
response  times  for emergency  vehicles to reach  the  residential
areas near the Project site.  The other $225,000 shall be earmarked
for the purchase of one (1) mobile  air quality monitoring van, for
use  by the  City  of  Jacksonville  Department  of  Regulatory and
Environmental Services to monitor ambient air for  concentrations of
non-criteria  pollutants.  The  City of Jacksonville shall use its
best efforts  to acquire such  an air quality monitoring van for a
purchase  price  less than $225,000.   If the City is successful in
                                8

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acquiring such a van  for  less  than $225,000,  the remaining funds
shall be applied toward the construction of the new fire station.
     10.  CBC agrees to provide onsite and off site improvements to
mitigate  impacts  across the Broward  River  from noise  and light
created  by the  Project.    Such  improvements  shall  be done  in
accordance with the landscape plan for the Project as approved by
the City of Jacksonville on April 2, 1993.  During the first three
years of  commercial  operation, CBC, after consultation with the
Citizens'  Committee,  Inc., will  provide  further mitigation for
noise and light impacts by providing additional onsite or offsite
improvements including improvements to the CBCP, which are intended
to reduce such impacts; however, no such further improvements and
related services,including consulting fees,shall exceed  a total
cost of $120,000.  Any such improvements to the Project shall not
occur  if  such  mitigation would  cause any  adverse  impacts to,
including filling of,  wetlands;  require adverse  modifications of
the stormwater management system or ponds; or cause a violation of
the conditions  of  certification,  applicable  law or the  City of
Jacksonville's landscape ordinance.
     11.  The Project shall be  constructed in conformance with the
conceptual Site Plan  attached  hereto  as Attachment  D.   This site
plan represents the facilities that are currently  to be constructed
and  operated pursuant to  the Site  Certification,  as modified
pursuant to these proceedings and this Agreement,  and the locations
of those  facilities.   Any  future modifications to this Site Plan
shall be made in accordance with applicable law and regulations.

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     12.  The parties agree that CBC will not be required to pursue
a federal National Pollutant Discharge Elimination System (NPDES)
or other permit for a surface water discharge permit for any Phase
II water treatment system as referenced in the Siting Board's Order
Instituting Modification Proceedings, dated June 17, 1992.  No such
Phase II water treatment system is proposed and any prior proposal
has been withdrawn in favor of the CBCP's zero discharge system.
     13.  The parties hereto agree not  to  oppose  the  issuance  of
any NPDES permit for the Project for the discharge of  storm water
or runoff caused by extreme rainfall events from the yard area and
storage area runoff ponds as shown on Attachment D,  provided that
the proposed discharge is  consistent  with  the  data  previously
submitted on or about April 4, 1993 to DER,  SJRWMD, and the City  of
Jacksonville  in  support  of  the  Petition for  Modification  of
Certification.  For purposes of this agreement, an extreme rainfall
event is defined as 1) a 50 year/24 hour storm for runoff from the
storage area; 2) a 22 year/24 hour storm for  runoff from the yard
area when  the CBCP  turbine  generator is  operating;  or 3)  a  12
year/24 hour  storm for  runoff from the yard area when  the CBCP
turbine generator is not operating.
     14.  The parties agree that there is no  basis to  require the
preparation  or  completion of  an environmental impact  statement
(EIS)  for the Project and that the parties will not request that
such an EIS be completed or prepared.
     15.   Any proposal to  plant trees as an  offset of  carbon
dioxide emissions from the Project, as proposed by a previous owner

                               10

                            .6-4

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of the stock of CBC, is satisfied by the improvements made pursuant
to the modified conditions of certification and this Agreement.
     16.  Seminole  Kraft stipulates  that  the  issuance  of  the
                                 i
original  certification  for  the CBCP  consumed  all  creditable
emissions resulting from the  shutdown of Seminole Kraft's existing
bark and power boilers.   Any creditable  emissions  resulting from
the  shutdown  of the  kraft  recovery boilers,  lime kilns,  smelt
dissolving tanks and slaker No. 3 shall be determined as provided
in Rule 17-212.400(a), F.A.C. and any permit issued for SK's three
proposed package boilers; but  SK acknowledges  that no creditable
emissions remain for sulfur dioxide.
     17.  The  Project and the Seminole Kraft  recycling mill are
independent sources of air emissions.   Accordingly, neither shall
be entitled  to receive  further  air  emission  credits  or offsets
based upon the  operating performance  of the other  below its air
emission  limits   established   in  the  attached  Conditions  of
Certification or  any air permit nor  shall there  be enforcement
taken  against  one of  these  parties  for violations  of  legal
requirements by the other of these two parties.
D. Other Provisions
     18.  With  respect to the first public  announcement of this
settlement agreement, the timing and wording of the first release
of this Agreement will be  reserved to the City of Jacksonville, the
Sierra Club,  Audubon Societies, Stafford Campbell and the Citizens'
Committee, after consultation  on  such  timing and  wording with
representatives of CBC and Seminole Kraft. Nothing released is to

                                11

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be derogatory of any party to this Agreement, nor inconsistent with
the terms of this Agreement.  Subsequent releases may be made  by
any party to  this Agreement at  its option, but in  all  instances
shall be consistent with the terms of this  Agreement.
     19.  The Parties agree  to cooperate in obtaining final  action
by the Siting Board on the proposed modification as  expeditiously
as possible.  The Parties agree that any presentation which they
may make  to the Hearing  Officer  and the  Siting Board shall  be
consistent with the  terms, provisions and spirit of this Agreement
and with  the  modified conditions  of  certification.  The parties
further agree to consult with one another in advance  of the meeting
of the Siting Board  concerning any  presentation they may make  to
the Board.
     20.    The  Citizens'  Committee  Inc.,   Sierra  Club,  Florida
Audubon Society, Duval Audubon Society, and  Stafford  Campbell agree
to return no later than April 30,  1993 to counsel for CBC and SK,
respectively, all copies of  all documents which  are  subject to any
confidentiality agreement in this case. -------
     21.  Within 30  days following final action by the Siting Board
approving the modifications of site  certification,  CBC will state
in writing  to the United States  Environmental  Protection  Agency
that it will  operate  the Project in  compliance with Section II of
the Conditions of Certification attached hereto  and  Paragraph 5 of
this Agreement  as though  those  provisions  were incorporated into
the  existing air  permit  for the  Project and accepts them  as
                                12

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federally enforceable.  CBC will contemporaneously provide a copy
of this letter to the other Parties to this Agreement.
     22.  As  an element of this Agreement, CBC has  provided the
Certificate attached as Attachment E.
     23.  All Parties waive any right to appeal, to challenge or to
take other  judicial or administrative  action to oppose,  in any
forum available, the issuance of a final revised air permit for the
Project which contains permit conditions that are  substantially
equivalent to the Conditions of Certification contained in Section
II of the conditions  of certification  in Attachment  B  hereto and
the additional  provisions of  Paragraph 5  herein.   The  Parties
reserve and do not waive the right to challenge or otherwise oppose
any  final  revised  air  permit  for  the Project that  contains
conditions substantially different from those addressed by section
II of  the conditions  of  certification  and  Paragraph  5  of  this
Agreement.
     24.  This agreement may be executed in multiple counterparts.
                                13
                             6-17

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PING BOYD GREENS  Sfl TEL:904-222-3898           May 14,93   10:24 No.006 P.02


   04/U/M   18:1T    »904 «90 1318        OFF CEN OOWSBL
           KUEREFORB,  the partie* hereto tlgnify their ratification of

           Settlement  Stipulation toy affixing their signature heretoi
      Staff o
Cititena' Coamittee/ Zno.

Byt	
   Barbara Brpward, Pread
Datet      44/3/Kf
                                   Sierra Club, Florida Audubon
                                   Society, The Duval Audubon
                                   Society,
                                                          Attorney
Cedar Bay Cmneration, Xno.

         ^^^	

         T
           c*ry ». eaag, Attorney
      Date i
      City of
      B:
      Datet
              iu
         •cott^snirley, Attorney^


      Date i
                                         Florida'Departaent of
                                      Richard T. Donelatr
                                      Aasistant Genera). Counsel
                                         Date
                                   St. Johns River Water
                                      Hanageaent District
                                         Charles  H.. Bovtwiok
                                   Datet
                                      14

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04/13/93  16:44    C904 630 1316
OFF GEN COUNSEL
12)003/003
    The   Ketate  of   William   c.
    Bostwick  and  Barnett  Banks
    Trust  Company, N.A.
                                     15

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      SETTLEMENT STIPULATION



          ATTACHMENT A




ALL MEMBERS OF CITIZENS' COMMITTEE

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O«.  12. 93   li:2 O.A.M  wMARGOL.  A.   I»CNNZNOTON         J> O 2



                                                          ATTACHMENT  A
                                 STATE OF FLORIDA
                       DIVISION OF ADMINISTRATIVE HEARINGS

     AES CEDAR BAY, INC. and  SEMINOLE
     KRAFT CORPORATION,

           Petitioner*.

     vs.

     DEPARTMENT  OF  ENVIRONMENTAL
     REGULATION,

           Respondent,

     and

     CITY OF JACKSONVILLE, DEPARTMENT OF      CASE NO. 88-5740
     COMMUNITY AFFAIRS, PUBLIC SERVICE
     COMMISSION, ST. JOHNS RIVER WATER
     MANAGEMENT DISTRICT, JACKSONVILLE
     ELECTRIC  AUTHORITY,  CHARLES w.
     BOSTWICK,   WILLIAM  C.  BOSTWICK,
     BA^
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      O *.  12.  63   li:2O .A.M  •* M A R G O L.   &.   PXNNXNGTON
i
                         1.     Barbara Broward, President
                         2.     Jack B. Lee, Vice President
                         3.     Charles. L Daniels, Vice President
                         4.     William C. Val Bostwick, Jr., Secretary
                         5.     Dorothy D. Mathias, Treasurer
                   FURTHER, THE AFFIANT SAYETH NOT.
            Swom to and subscribed before me
            this 12th day of April, 1993.


                  \VsP r f]         i y   j t^
            SSgnatuW of Notary Public     "0
                 Mararet A  Z.
            Name of Notary (ry?*, M.I* ot &«
            Commission Number
            My Commission Expires

                 NOTARY PUBLIC, STATE OF FLORIDA
                 My commtttsn «xplr« Ab-g. 30. 1993
                 •ended tnru ^(ttirMn . B*eM Ajtnoy
                                                         LISA BARCLAY Coorar—


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            SETTLEMENT STIPULATION

                 ATTACHMENT B

         CONDITIONS OF CERTIFICATION
                APRIL 7,  1993
(These Conditions of Certification, which have been
 updated,  are not included here.  They are available
 on request from Reinz Mueller, Chief, Environmental
 Policy Section; FAB-4;  U.S. EPA Region IV; 345 Courtland
 Street, NE;  Atlanta, GA  30365)

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                                                            . (
State of Florida Department of Environmental Protection
CBCP/Seminole Kraft Corp.
Cedar Bay Cogeneration Project
PA 88-24A

(Revised 4/12/93)


                    CONDITIONS OF CERTIFICATION

                           TABLE OF CONTENTS


                                                          PAGE NO.

Z.       GENERAL                                              1

XI.      -\IR                                                *  1
         A.  Emission Limitations for CBCP Boilers            1
             1.     Fluidized Bed Coal Fired Boilers (CFB)    1
             2.     Coal Fired Boiler Controls                3
             3.     Flue Gas Emissions                        3
             4.     Ammonia (NH) Slip from* Exhaust Gases      4
             5.     Visible Emissions                         4
             6.     Compliance with permit limits             4
             7.     CFB subject                               4
             8.     Compliance Tests                          4
             9.     Continuous Emission Monitoring            5
             10.    Operations Monitoring                     6
             11.    Reporting for each CFB                  . 6
             12.    Submitting Changes for. Approval           7
             13.    All Records of Documentation File         7
                    Minimum Years
             14.    Permittee Subject to Provisions of        7
                    Rule 17-210.700
             15.    Permittee Subject to Provisions of        7
                    Rule 17-210.650
             16.    Permittee Subject to Provisions of        7
                    Rule 17-4.16Q
         B.  CBCP Material Handling and Treatment             8
         C.  Requirements for the Permittees                 10
         D.  Contemporaneous Emission Reductions             11
         E.  SK Steam Boiler Emissions                       12

III.     WATER DISCHARGES    .     '                           13
         A.  Plant Effluents and Receiving Body of Water     13
             1.     Discharge of Cooling System              13
             2.     Zero Discharge Plan                      13
             3.     Receiving Body of Water                  13
             4.     Point of Discharge                       13
             5.     Chemical Wastes from CBCP                13
             6.     SKC Shut Down Through Cooling System     13
             7.     Storm Water Runoff                       14
             8.     Sanitary Wastes                          15
         B.  Water Monitoring Programs                       15

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IV.      GROUND WATER                                        17
         A.  Water Well Construction Permit                  17
         B.  Well Criteria, Tagging and Operating Plan       17
     •  -—C.  Maximum Annual Withdrawals                 .     is
         D.  Water Use Transfer                              18
         E.  Emergency Shortages                             18
       —F.  Monitoring and Reporting                        18
       —G.  Ground Water Monitoring Requirements            20
         H.  Leachata                                        21
         Z.  Water Use Audit                                 22
       —J.  Water Conservation Awareness Program            22
V.       CONTROL MEASURES DURING CONSTRUCTION                23
         A.  Storm Water Runoff           *                  23
         B.  Sanitary Wastes                                 23
         C.  Environmental Control Program                   23
         D.  Construction Dewatering Effluent      .          24
VT.      SAFETY                                              24
VII.     SCREENING                                           24
VTII.    TOXIC, DELETERIOUS, OR HAZARDOUS MATERIALS          24
ZZ.      SOLZD WASTE STORAGE AND DISPOSAL                    24
Z.       CHANGE ZN DISCHARGE                                 25
ZZ.      NONCOMPLZANCB NOTIFICATION                          26
XII.     FACILITIES OPERATION    .                            26
ZZZZ.    ADVERSE ZXPACT                                      26
XIV.     RIGHT OF ENTRY                                      26
XV.      REVOCATION OR SUSPENSION                            27
XVI.     CIVIL AND CRIMINAL LIABILITY                        27
XVTI.    PROPERTY RIGHTS                                     27
XVIII.   8EVERABILZTY                                        27
XVTV.    DEFINITIONS                                         28
ZZ.      REVIEW OF SZTE CERTIFICATION                        28
ZZZ.     MODIFICATION OF CONDITIONS                          28
ZZZZ.    FLOOD CONTROL PROTECTION                            28
ZZZZZ.   EFFECT OF CERTIFICATION                             29

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  XXXV.    NOISE                                              29



& XXV.     USB OF WATER TOR COOLINO PURPOSES                   29



  XXVI.    ENFORCEMENT                                        30



  XXVZZ.   ENDANGERED AND THREATENED 8PECZES                   30



 ^.XXVXXX.  ENVIRONMENTALLY SENSITIVE LAND ACQUISITION          30



  XXIX.    TRANSFER OT CERTIFICATION                           35
                              6-27

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Modified 4/12/93                                     PA 88-24A
    STATE 07 PLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION
       CEDAR BAY COGENERATION, INC./8EMINOLE KRAFT CORP.
                CEDAR BAY COGENERATION PROJECT
                           PA 88-24A

                  CONDITIONS OF CERTIFICATION

     When a condition is intended to refer to both Cedar Bay
Cogeneration, Inc. (CBC) and Seminole Kraft Corp., the tern
"CBC/SK" or "permittees'* will be used.  When a condition is
intended to refer to the "Cedar Bay Cogeneration Project" the
terms "Cedar Bay Cogeneration Project", "CBCP",  or "Project"
will be used.

Where a condition applies only to Cedar Bay Cogeneration, Inc.
the term Cedar Bay Cogeneration, Inc."(CBC) or the term
"permittee," where it is clear that "CBC" is the intended
responsible party, will be used.  Similarly, where a condition
applies only to Seminole Kraft Corp., the term "Seminole Kraft
Corp." or the abbreviation "SK" or the term "permittee," where
it is clear that SK is the intended responsible party, will be
used.  The Department of Environmental Protection may be
referred to as DEP or the Department.  RESD represents the City
of Jacksonville, Regulatory and Environmental Services
Department.  SJRWMD represents the St. Johns River Water
Management District.


I.        GENERAL

          The construction and operation of CBCP shall be in
accordance with all applicable provisions of at least the
following regulations of the Department:  Chapters 17-210
through 17-297, 17-302, 17-4, 17-256  (Opening Burning), 17-601,
17-702, 17-312, 17-532, 17-550, 17-555, 17-25, 17-610, 17-660,
and 17-772, Florida Administrative Code (F.A.C.) or their
successors as they are renumbered.  '

ZI.       AIR

          The construction and operation of CBCP shall be in
accordance with all applicable provisions of Chapters 17-210
through 17-297, F.A.C.  In addition to the foregoing, CBCP
shall comply with the following conditions of certification as
indicated.

          A.   Emission Limitations for CBCP Boilers

          1.   Fluidized Bed Coal Fired Boilers  (CFB)

               a.   The maximum coal  charging rate of each CFB
shall neither exceed 104,000 lbs/hr., 39,000 tons per month  (30
consecutive days), nor 390,000 tons per year  (TPY).  This
reflects a combined total of 312,000  lbs/hr., 117,000 tons per
month, and 1,170,000 TPY for all three CFBs.

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Modified 4/12/93                                     PA 88-24A
               b.   The maximum charging rate to each of two
CFBs of short fiber recycle rejects from the SK recycling pro-
cess shall not exceed 210 yd3/day vet and 69,588 yd3/yr wet.
This reflects a combined total of 420 yd3/day vet and 139,176
yd3/yr vet for the tvo CFBs that fire recycle rejects. The
third CFB vill not utilize recycle rejects, nor vill it be
equipped with handling and firing equipment for recycle rejects.

               c.   The maximum heat input to each CFB shall
not exceed 1063 MMBtu/hr.  This reflects a combined total of
3189 MMBtu/hr. for all three units.

               d.   The sulfur content of the coal shall not
exceed 1.2% by weight on an annual basis.  The sulfur content
shall not exceed 1.7% by veight on a shipment (train load)
basis.

               e.   Auxiliary fuel burners shall be fueled only
with No. 2 fuel oil with a maximum sulfur content of 0.05% by
veight.  The fuel oil shall normally only be used for startups.
During commercial operation the maximum annual oil usage shall
not exceed 1,900,000 gals./year.  The maximum heat input from
the fuel oil shall not exceed 380 KKBtu/hr. for each of the
CFBs.

               f.   The CFBs shall be fueled only with the
fuels permitted in Conditions II.A.la, Ib, and le above.  Other
fuels or wastes shall not be burned without prior specific
written approval of the Secretary of DEP pursuant to condition
XXI, Modification of Conditions.

               g.   The CFBs may operate continuously, i.e.,
8760 hrs/yr, but shall not exceed 25.98 x 10* MMBtu/yr total
annual heat input.

               h.   To the extent that it is consistent with
Condition II.A.lb. and the following, CBCP shall burn all of
the short fiber rejects generated by Seminole Kraft in
processing recycled paper.  No less than ninety (90) days prior
to completion of construction, CBCP shall submit a plan to DEP
for conducting a 30-day test burn within one year after initial
compliance testing.  That test burn shall be designed to
ascertain whether the CFBs can burn the rejects as supplemental
fuel without exceeding any of the limitations on emissions and
fuel usage contained in Condition II.A. and without causing any
operational problems which would affect the reliable operation
(with customary maintenance) of the CFBs and without violating
any other environmental requirements.  CBCP shall notify DEP
and the Regulatory and Environmental Services Department (RESD)
at least thirty (30) days prior to initiation of the test burn.
The results of the test burn and CBCP's analysis shall be
reported to DEP and to the RESD within forty-five (45) days of
completion of the test burn.  DEP shall notify CBCP within
thirty (30) days thereafter of its approval or disapproval of
any conclusion by CBCP that the test burn demonstrated that the
rejects can be burned in compliance with this Condition of
Certification.

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 Modified  4/12/93
PA 88-24A
           2.    Coal Fired Boiler Controls

           The emissions from each CFB shall be controlled using
 the following systems:

           a.    Limestone injection and  fuel sulfur limitations,
 for control of sulfur dioxide and acid  gases.

           b.    Baghouse, for control of particulate matter.

           c.    CBCP shall conduct a test to determine whether
 substantial additional removal  of mercury  can be  obtained through
 a carbon injection system for mercury removal, as described  in
 Exhibit 74 of the administrative record for the Lee County
 Resource Recovery Facility, which feeds carbon reagent  into  the
 CFB exhaust stream prior to the baghouse.  Within one hundred
 eighty (180)  days after initial compliance testing,  CBCP shall
 conduct a test on one CFB to compare mercury emissions  to the
 atmosphere with and without carbon injection.  The test program
 will include  the testing of carbon injection between the boiler
 and the fabric filter.  Carbon  forms to be tested may  include
 activated carbon with or without additives and pulverized coal
 with or without additives.  After consultation with the DEP,
 RESD, and EPRI, CBC  shall submit a mercury control test protocol
 to DEP for approval  by December 1,  1993.   Results of the test
 shall be submitted to the DEP within  90 days of  completion.

           d.    Selective Non-catalytic  Reduction (SNCR) for
 control of NOx.

           e.    Good  combustion  characteristics,  which  are  an
 inherent part of the CFB  technology,  for  control of  carbon
'monoxide and volatile organic compounds.

           3.    Flue  gas  emissions  from each  CFB shall  not
 exceed the following:

                                Emission Limitations
                                Ibs/hr.       T*Y     TPY for 3 CTBs
troo. xubaub
''NOX-
SO5
/
woe •
PM .

H2S04 mist
Fluorides
Lead
Mercury
Beryllium
^.^9 / rw^-f» •- *•
0.175, *
0.17 J
0.24 .
0.20
0.015
0.018
0.018
4.66C-04
7.44e-04
6.03e-05
2.89e-05
8.70e-06
_•_ Ad 0 g ^-K^. •
186 ! ,
180.7 J
255.1 *
—
16.0
19.1
19.1
0.50
0.79
0.06
0.03
0.01
758
736.1
—•
866
65
78
78
2.0
3.2
0.26
0.13
0.04
2273
2208
~~
2598
195
234
234
6.1
9.7
0.78
0.38
0.11
  [Note:  TPY represents a 93% capacity factor.]

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Modified 4/12/93                    .                 PA 88-24A
 /,\       Eight-hour rolling average, except for initial and annual
          compliance tests and the CEM certification, when  1-hour
          standard applies.
 (a)       Thirty-day rolling average.
 (3)       Three-hour rolling average.
 (4)       Twelve-Month rolling average  (MRA) .

          4.   Ammonia  (KH3> slip' from exhaust gases shall  not
 exceed 10 ppmvd when burning coal at  100% capacity and  30 ppmvd
 when burning  oil.

          5.   Visible emissions  (VE) shall  not exceed  20%  opacity
 (6 min.  average) , except for one  6 minute period per hour when VE
 shall not exceed  27% opacity pursuant to 40  CFR 60.42a.
    6.   Compliance with the emission limits shall be
ined by EPA reference method tests included in the /July
.dete
 19921 version of 40 CFR Parts 60 and 61,  Rule 17-297,  F.A.C.,  ana
"listed in Condition No. II. A. 8  of this permit or by equivalent
 methods after prior written  DEP approval.   In addition,  compliance
 with the emission limitations in Condition No. II:A.3 for CO, NOX
 and S02 and with the opacity requirements  in Condition No. II. A. 5
 shall be determined with the Continuous  Emission Monitoring Systems
 (CEMs) identified in Condition  No. II. A. 9.-

           7.   The CFBs are  subject to 49  CFR Part 60, Subparts A
 and Da; except that where requirements within this certification
 are more restrictive,  the requirements of  this certification shall
 apply.

           8.   Compliance Tests for each CFB

           a.   Initial and subsequent compliance tests for PM/PMio,
 SO?, NOx, CO, VOC, lead, fluorides, ammonia, mercury, beryllium and
 H2S04 mist shall be conducted in accordance with 40 CFR 60.8  (a),
 (b),  (c), .(d), (e), and (f ) .

           b.   Annual compliance tests shall be performed for PM,
 CO, S02 and NOx, commencing no  later than  12 months from the
 initial test.

           c.   Compliance tests shall be performed for mercury
 (Hg) , beryllium (Be) , and lead  (Pb) until  three consecutive tests
 (including, if successful, the  initial compliance test)  are within
 the annual emission limits specified in  Condition II. A. 3. above.
 Such tests shall occur, as necessary, in the first, fifth and tenth
 years and additional successive five year  intervals following
 commercial operation of the Project.

           d.   Initial and annual visible  emissions compliance
 tests shall be determined in accordance  with 40 CFR 60.11(b) and
 (e).

           e.   The compliance tests shall  be conducted between
 90-100% of the maximum licensed capacity and firing rate for each
 permitted fuel.

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Modified 4/12/93                            •         PA 88-24A
          f.   The following test methods and procedures of Rule
17-297, F.A.C., and 40 CFR Parts 60 and 61 or other DEP approved
methods with prior DEP approval, in writing, shall be used for
.compliance testing:
(1)  Method 1 for selection of sample site and sample traverses.
<2)  Method 2 for determining stack gas flow rate.
(3)  Method 3 or 3A for gas analysis for calculation of percent 02
and C02*
(4)  Method 4 for determining stack gas moisture content to convert
the flow rate from actual standard cubic feet to dry standard cubic
feet.
(5)  Method 5 or Method 17 for particulate matter.
(6)  Method 6, 6C, or 8 for S02.
(7)  Method 7, 7A, 7B, 7C, 7D, or 7E for nitrogen oxides.
(8)  Method 8 for sulfuric acid mist.
(9)  Method 9 for visible emissions, in accordance with 40 CFR
60.11  and Appendix A.
(10)   Method 10 for CO.
(11)   Method 12 for lead.
(12)   Method 13A or 13B for fluorides.
(13)   Method 19 for sulphur dioxide removal  efficiency pursuant to
40 CFR 60.48a.
(14)   Method 18 or 25 for VOCs.
(15)   Method 101A  or EPA Method 29 for mercury.
(16)   Method 104 for beryllium.
 (17)   Method 201 or 201A for  PM10 emissions.
 (18)   Ammonia  (NHs) Method to be determined by the Department.
           9.    Continuous Emission Monitoring for each  CFB
CBCP shall install, certify,  calibrate,  operate,  and maintain
continuous emission monitoring  systems for opacity,  SO2,  NOX,  CO,
and 02 or CO?,  pursuant to all  applicable requirements  of Rule
17-296.800, F.A.C., Chapter  17-297,  F.A.C.,  40 CFR  60 Subpart A,  40
CFR 60 Subpart Da, 40 CFR 60  Appendix B,  and 40  CFR 60  Appendix F.
These CEKS shall be used to  determine compliance with the emission
limitations in Condition No.  II.A.3  for  CO,  NOX,  and SO2  and with
                                    6

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Modified 4/12/93                                     PA 88-24A



the opacity requirements in Condition No.  II.A.5.   The permittee
nay elect to install, certify, calibrate,  operate,  and maintain
multiple span continuous emission monitoring systems for sulfur
dioxide and nitrogen oxides providing certification tests and
calibrations are performed for each span.   Each of the continuous
emission monitoring systems for sulfur dioxide and nitrogen oxides
shall continuously record data on a span that satisfies the
requirements of 40 CFR 60.47a.  Any exception to the above must be
specifically authorized by DEP in writing and in accordance with
state and federal regulations.

          a.   CEMS data shall be recorded and reported in
accordance with Chapter 17-297, F.A.C., and 40 CFR 60.49a and 60.7.
A record shall be kept for periods of startup, shutdown and
malfunction.

          b.   A malfunction means any sudden and unavoidable
failure of air pollution control equipment or process equipment or
of a process to operate in a normal or usual manner.  Failures that
are caused entirely or in part by poor maintenance, careless
operation or any other preventable upset condition or preventable
equipment breakdown shall not be considered malfunctions.

          c.   The procedures under 40 CFR 60..13 shall be followed
for installation, evaluation and operation of all CEMS.

          d.   Opacity monitoring system data shall be reduced to
6-minute averages, based on 36 or more data points, and gaseous
CEMS data shall be reduced to 1-hour averages, based on 4 or more
data points, in accordance with 40 CFR 60.13(h).

          e.   For purposes of reports required under this
certification, excess emissions are defined as any calculated
average emission concentration, as determined pursuant to Condition
No. II.A.11 herein, which exceeds the applicable emission limit in
Condition No. II.A.3.

          f.   The permittee  is subject to all applicable
provisions of Rule 17-4.130,  Plant Operation-Problems.

         10.   Operations Monitoring for each CFB

          a.   Devices shall  be installed to continuously monitor
and record steam production,  and flue gas temperature at the exit
of the control equipment.

          b.   All coal and No. 2 fuel oil usage shall be recorded
on a 24-hr  (daily) basis for  each CFB.  Recycle rejects usage  on a
volumetric basis shall be estimated and recorded for each 24-hour
period in which rejects are burned.

         11.   Reporting for  each CFB

          a.   A minimum of thirty  (30) days prior written  notifi-
cation of compliance testing  shall be given to DEP's N.E. District-
office and to the RESD office, in accordance with  40 CFR  60.8.


                                   6-33

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Modified 4/12/93                                     PA 88-24A
          b.   In accordance with Rule 17-297.570, F.A.C., the
results of compliance test shall be submitted to the RZSD office
within 45 days after completion of the last test run.

          c.   The owner or operator shall submit excess emission
reports to RZSD, in accordance with Rule 17-210.700, F.A.C., and 40
CFR 60.7(c) and (d).  The reports shall include the following:

               (1)   The magnitude of excess emissions computed in
accordance with 40 CFR 60.13(h), any conversion factors used, and
the date and time of commencement and completion of each period of
excess emissions (40 CFR 60.7(c)(l)>.

               (2)   Specific identification of each period of
excess emissions that occurs during startups, shutdowns, and
malfunctions of the furnace boiler system.  The nature and cause of
any malfunction (if known) and the corrective action taken or
preventive measures adopted (40 CFR 60.7(c)(2)).

               (3)   The date and time 'identifying each period
during which the continuous monitoring system was inoperative
except for zero and span checks, and the nature of the system
repairs or adjustments (40 CFR 60.7(c) (3))..

               (4)   When no excess emissions have occurred or the
continuous monitoring system has not been inoperative, repaired, or
adjusted,  such information shall be stated in the report  (40 CFR
60.7(c)(4)).

               (5)   The owner or operator shall maintain a file of
all measurements, including continuous monitoring systems
performance evaluations; monitoring systems or monitoring device
calibration; checks; adjustments and maintenance performed on these
systems or devices; and all other information required by this
permit recorded in a permanent form suitable for inspection (40 CFR
60.7(e)).

          d.   Annual and quarterly reports shall be submitted to
RZSD as per Rule 297.500, F.A.C.

         12.   Any change in the method of operation, fuels
utilized,  equipment, or operating hours or any other changes
pursuant to Rule 17-212.200, F.A.C., defining modification, shall
be submitted for approval to DEP's Bureau of Air Regulation.

         13.   All records of documentation shall be kept on file
for a minimum of 3 years pursuant to Rule 17-4.160(4), F.A.C.

         14.   The permittee is subject to all applicable
provisions of Rule 17-210.700, F.A.C., Excess Emissions.

         15.   The permittee is subject to all applicable
provisions of Rule 17-210.650, F.A.C., Circumvention.

         16.   The permittee is subject to all applicable~
provisions of Rule 17-4.160, F.A.C., Permit Conditions.

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Modified 4/12/93                                     PA 88-24A
          B.   CBCP - Material Handling and Treatment

          1.   The naterial handling and treatment operations
including coal and limestone unloading buildings,  coal and
limestone reclaim hoppers, coal crusher house, limestone dryer,  fly
and bed ash silos, ash pelletizer, pellet curing silo, coal and
limestone day silos, conveyors, storage areas and related
equipment, may be operated continuously, i.e. 8760 hrs/yr, except
that the limestone crushers/dryers may be operated for a maximum of
11 hours per day (maximum of 2920 hrs/yr) at maximum capacity.

          2.   The material handling/usage rates for coal,
limestone, fly ash, and bed ash shall not exceed the following:

                                  Handling/Usage Rate
          Material                TPM	1ZX

          Coal                  117,000      1,170,000
          Limestone              27,000        320,000
          Fly Ash                28,000        336,000
          Bed Ash                 8,000         88,000

          Note: TPM is tons per month based on 30 consecutive days,
TPY is tons per year.

          3.   The VOC emissions from the maximum No. 2 fuel oil
utilization rate of 240 gals/hr., and 700,800 gals/year for the
limestone dryers; and 8000 gals/hr., and 1,900,000 gals/year for
the three boilers are not expected to be significant.

          4.   Material handling sources shall be regulated as
follows:

          a.   The material handling and treatment area sources
with either fabric filter or baghouse controls are as follows:

          Coal Crusher Building
          Coal Silo Conveyor
          Limestone Pulverizer/Conveyor
          Limestone Storage Bin
          Bed Ash Hopper
          Bed Ash Silo
          Fly Ash Silo
          Bed Ash Bin
          Fly Ash Bin
          Pellet Vibratory Screen
          Pelletizing Ash Recycle Tank
          Pelletizing Recycle Hopper
          Cured Pellet Recycle Conveyor
          Pellet Recycle Conveyor

          The emissions from the above listed sources are subject
to the particulate emission limitation requirement of 0.003 gr/dscf
(applicant requested limitation which is more stringent than what
is allowed by Rule 17.296.711, F.A.C.).  Since these sources are
RACT standard type, then a one-time verification test on each

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Modified 4/12/93                                     PA 88-24A
source shall be required for PM mass emissions to demonstrate that
the baghouse control systems can achieve the 0.003 gr/dscf.  The
performance tests shall be conducted using EPA Method 5 pursuant to
Rule 17-297, F.A.C.,and 40 CFR 60, Appendix A (July, 1991 version).

          b.   The PM emissions from the following process,
equipment, and/or facility in the material handling and treatment
area sources shall be controlled using vet suppression/removal
.techniques as follows:

          Coal Car Unloading
          Ash Pellet Hydrator
          Ash Pellet Curing Silo
          Ash Palletizing Pan

          The above listed sources are subject to a visible
emission  (VE) and a particulate matter (PM) emission limitation
requirement of 5% opacity and 0.01 gr/dscf (applicant requested
limitation, which is more stringent than what is allowed by rule),
respectively, in accordance with Rule 17-296.711, F.A.C.  Initial
and subsequent compliance tests shall be conducted for VE and PM
using EPA 9 and 5, respectively, in accordance with Ruj,a 17-297,
F.A.C., and 40 CFR 60, Appendix AITjuly, 1991 versionT.]

          5.   Visible Emissions (VE) shall not exceed 5% opacity
from any  source in the material handling and treatment area listed
in Condition II. B.4., in accordance with Rule 17-296.711(2)(a),
F.A.C.  After the compliance tests have been performed, neither DEP
nor RESD  will require particulate matter mass tests in accordance
with EPA  Method 5 unless the VE limit of 5% opacity is exceeded for
a given source, or unless DEP or RESD, based on other information,
has reason to believe the particulate emission limits are being
violated  in accordance with Rule 17-297.620(4), F.A.C.

          6.   All sources subject to visible emissions and
particulata matter mass emissions performance tests shall conduct
them concurrently, except where inclement weather interferes.

          7.   The maximum emissions from each of the limestone
dryers while using oil shall not exceed the following  (based on
AP-42 factors, Table 1, 3-1, Industrial Distillate, 10/86):

                                Estimated Limitations
Pollutant
PM/PMio
S02
CO
NOX
voc
Ibs/hr.
0.24
0.85
0.60
2.40
0.05
TPY
0.32
1.15
0.81
3.25
0.06
TPY for 2
0.64
2.3
1.62
6.5
0.12
drv«rs

           Visible emissions from the  dryers  shall  not  exceed 5%
 opacity.

           8.    The maximum sulfur  content  of No. 2 fuel oil shall
 not exceed 0.05% by weight.  The maximum firing rate of No. 2 fuel
 oil for each  limestone dryer shall not exceed 120  gals/hr., or

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Modified 4/12/93                                     *A 88-24A



350 400 qals/year.  This reflects a combined total fuel oil firing
rate of 240 gals/hr., and 700,800 gals/year, for the two dryers.

          9.   Initial and annual PM and Visible Emission
compliance tests for all the emission points in the material
handling and treatment area, including but not limited to the
sources SDftci£ied_inthi» permit, shall be conducted in accordance
with theVuly 1, 1991)version of 40 CFR 60, Appendix A, using EPA
Methods 5 and 9, respectively.

         10.   Compliance test reports shall be submitted to RESD
within 45 days of test completion in accordance with Rule
17-297.570 Of the F.A.C.

      '  11.   Any changes in the method of operation, raw
materials processed, equipment, or operating hours or any other
changes pursuant to F.A.C. Rule 17-212.200, defining modification,
shall be submitted for approval to DEP's Bureau of Air Regulation
(BAR).

          C.   Requirements For the Permittees

          1.   Beginning one month after certification, CBCP shall
submit to RESD and DEP's BAR, a quarterly status report briefly
outlining progress made on engineering design and purchase of ma}or
equipment,  including copies of technical data pertaining to the
selected emission control devices.  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.  Such disapproval shall be issued within 30 days
of receipt  of the technical data.

          2.   CBCP  shall report any delays in construction and
completion  of the project which would- delay-commercial operation by
more than 90 days to the RESD office.

          3.   Reasonable precautions to prevent  fugitive
particulate emissions during construction,  such as coating of roaas
and  construction  sites used by contractors, regrassing or watering
areas  of disturbed soils, will be taken by  CBCP.  CBCP is subject
to all applicable provisions of Rule  17-296.310(3),  F.A.C.,
Unconfined  Emissions of Particulate Matter.

          4.    Fuel  shall not be burned in  any CBCP  unit unless the
control devices are  operating properly, pursuant  to  40 CFR Part 60
Subpart Da.

          5.    The maximum  sulfur content  of the  No. 2 fuel oil
•utilized  in the CFBs and the two unit limestone dryers shall  not
exceed 0.05 percent  by weight.   Samples shall be  taken^ox^each fuel
«n  «Mp«?nt%*e*ivftd and shall  be  analvzed^for^snl f\ir content ana
Keating value!—Records of  the  analyses shall be  kept a minimum of
tKree years to  be available for DEP and RESD inspection.



                                    6-37
                               in

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Modified  4/12/93                                     PA 88.-24A
           6.    Coal  fired in the CFBs shall have a sulfur content
 not to  exceed 1.7 percent by weight on a shipment (train load)
 basis.   Coal  sulfur  content shall be determined and recorded in
 accordance with 40 CFR 60.47a.

           7.    CBC shall maintain a daily log of the amounts and
-types of fuel used and copies of fuel analyses containing •
 information on sulfur content and heating values.

           8.    CBCP  shall provide stack sampling facilities as
 required by Rule 17-297.345 F.A.C.   ?

           9.    Prior to commercial/operation of each source, the
 permittee shall submit to the(B~AlT)a  standardized plan or procedure
 that will allow that permittee^ttr monitor emission control
 equipment efficiency and enable the  permittee to return
 malfunctioning equipment to proper operation as expeditiously as
 possible.

        •  10.    All CBCP records of documentation shall  be kept  on
 file for a minimum of three years pursuant  to Rule  17-4.160(14),
 F.A.C.

           D.    Contemporaneous  Emission Reductions

           This certification and  any individual air permits issued
 subsequent to the final order of  the Board certifying the power
 plant site under 403.509,  T.S., shall require,  that the following
 Seminole Kraft Corporation sources  be permanently  shut down and
 made incapable of operation,  and shall turn in their operation
 permits to the Division of Air Resources Management's Bureau of Air
 Regulation,  within 30 days of written confirmation by DEP of the
 successful completion of -the initial compliance tests on the CBCP
 boilers: the No. 1 PB  (power boiler),  the No.  2 PB,  the No. 3 PB,
 the No.  1 BB  (bark boiler),and the No. 2 BB.   RESD shall be
 specifically informed in writing withiiv thirty.days after- eaclv ^
 individual shut down of the above referenced equipment.  Within one
 year of  surrender of operating permits as provided above,  SK shall
 have completed the  following steps to ensure compliance with this
 condition:

           Remove all oil guns
           Remove motors and selected conveyor parts in wood feed
              system  for bark boilers
           Dismantle stacks
           Disconnect boiler feedwater pumps
           Sever fuel line connections
           Remove fan motors

           These sources shall  not, under any circumstances, be
 restarted, refurbished or re-permitted as  new or existing sources,
 at the SK or CBCP site.

 This requirement shall operate as a joint  and individual
 requirement  to assure common control  for purpose of ensuring that
 all commitments relied on are  in fact fulfilled.


                                    3-3*

                                11

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Modified 4/12/93                                     PA 88-24A
          E.   SK Steam Boiler Emissions

          1.   This certification and any individual air permits
issued by the Department subsequent to the final order of the Board
certifying the power plant site under Section 403.509, F.S.,  shall
incorporate the following limitations on the total tonnage of the
specified criteria pollutants allowed to be emitted annually by any
natural gas-fired boiler or combination of boilers constructed and
operated by SK to provide up to 375,000 Ibs/hr of steam for use in
its recycled paper process:

                     Teas Per Year

                     CO   553
                     NOX  310
                     SO2   25, except as provided in (2) below

          2.   In the event that the ceiling for S02 is expected to
be exceeded due to unavailability of natural gas caused by factors
beyond the control of SK, SK may notify the Department that it must
exceed the ceiling as provided herein; and emissions of SO2 during
the period of such curtailment shall not be counted against the
yearly emissions ceiling of 25 tons unless administrative
proceedings result in a finding that the exceedance was within
Seminole Kraft's control.  In no event shall the annual emissions
of S02 from the steam boilers referenced above exceed a ceiling of
41 tons per year.

          3.   The notice shall include a statement or reasons for
the request and supporting documentation, and shall be published by
SK, without supporting documents, in a newspaper of general
circulation in Jacksonville, as defined in Section 403.5115(2),
F.S.  The filing and publication of the notice no later than 7 days
following the date of exceedance, shall preclude any finding of
violation by DEP until final dispositionof any administrative
proceedings.
                              12

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Modified 4/12/93                     .                PA 88-24A



III.      WATER DISCHARGES

          Any discharges into any waters of the State during
construction and operation of CBCP shall be in accordance with all
applicable provisions of Chapters 17-301, 17-302 and 17-660,
F.A.C., and40 CFR, Part 423, Effluent Guidelines and Standards for
Steam Electric Power Generating Point Source Category, except as
provided herein.  Also, CBCP shall comply with the following
conditions of certification:

          A.   Plant Effluents and Receiving Body of Water

          For discharges made from the CBCP power plant site the
following conditions shall apply:

          1.   CBCP shall not discharge any cooling system,
demineralizer regeneration,  floor drainage or other process
wastewaters from the operation of the CBCP facility into any waters
of  the State.  CBCP shall install a closed-loop cooling water
svstem in accordance with technical specifications set forth in the
Zero Discharge System Plan submitted by CBCP to the Department.

          2.   Pursuant to the Zero Discharge Plan, CBCP shall make
available to Seminole Kraft  up to 500 gpm of reclaimed water that
has been treated to a quality satisfactory for use in Seminole
Kraft's cooling tower.

          3.   Receiving  Body of Water - The receiving bodies of
water  for storm water discharges have been determined by the
Department  to  be those waters of the St. John's River (during
construction only) or the Broward River  and any Ot5".^f".   „..
affected which are considered to be waters of  the State within  the
definition  of  Chapter  403,  Florida Statutes  (F.S.).

          4.    Point of Discharge  (POD)  -  The  point  of discharge
has been  determined  by the  Department to be wherethe storm water
 effluent  physically  enters  the  waters of the  State  in the St.
 John's River  (during construction) via  Outfall OSN  001 and Broward
 £v^r (during construction  and  operation)  via  Outfall OSN 003 and
 OSN 008.

           5.    Chemical Wastes  from  CBCP - All low  volume wastes
 (demineralizer regeneration, floor drainage,  labs drains,  and
 similar wastes) and chemical metal cleaning wastes  shall be
 collected and treated in the the zero discharge treatment system  or
 disposed of off-site.

           6.    Seminole Kraft Corporation (SKC)  shall shut down the
 mill's once through cooling system within 10 days after vrittjn
 notification by DEP of the successful completion of the initial
 Compliance tests on the CBCP boilers conducted pursuant to ,
 Condition II.A.7.  SKC shall inform the DEP Northeast District
 Office of the shutdown and  surrender all applicable operating
 permits for that facility within 21 days of such notification.

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Modified 4/12/93                                     PA 88-24A
          7.   Storm Water Runoff

          a.   Construction -   During construction there shall
be no discharges from the stormwater basins for storms less
than the ten-year, twenty four-hour storm event.  Any discharge
from the storm water runoff collection system from a storm
event less than the once in ten year, twenty-four hour storm
shall meet the following limits and shall be monitored at OSNs
003 and 008 by a grab sample once per discharge, but not more
often than once per week:

                                     Discharge Limits
Effluent Chaxaeteristie     *     Instantaneous Kaziaum
Flov (MGD)                                 Report
TSS (mg/1)                                 '  50
pH                                        6.0-9.0

All applicable discharge limitations, described in Part X of
the NPDES permit  (FL0041173) for stormwater discharges during
the period of construction from this facility, shall apply
under this permit and be reported to the Department as part of
the Monthly Operation Report.

          b.   Operation

          1.   Yard Area Runoff - During normal plant
operation, necessary measures shall be used to settle, filter,
treat or absorb silt-containing or pollutant-laden storm water
runoff to limit the suspended solids to 50 mg/1 or less at OSN
003 during rainfall periods greater than the 22-year, 24-hour
rainfall.  During periods of operation when the CBCP is
off-line, these necessary measures, as specified above, shall
be used during rainfall periods greater than a 12-year,. 24-hour
storm.  The discharge shall comply with all the monitoring
requirements for Yard Area Runoff specified in Part I of NPDES
Permit FL0041173 for this facility.

          2.   Storage Area Runoff - During operation there
shall be no discharges from the stormwater basins for storms
less than the fifty-year, twenty four-hour storm event.  Any
discharge from the storm water runoff collection system from a
storm event less than the once in 50 year, twenty-four hour
storm shall meet the limits in 7.a. above and shall be
monitored at OSN  008 by a grab sample once per discharge, but
not more often than once per week.  The discharge shall comply
with all the monitoring requirements for the Coal, Limestone,
and Ash Storage Area specified in Part I of NPDES Permit
.FL0041173 for this facility.

          c.  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 9.0 in the discharge
to the St. Johns River and 6.5 to 8.5 in the Broward River.
                              1 A

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Modified 4/12/93                                    -PA 88-24A
          d.  Special consideration must be given to the
control of sediment laden runoff resulting from storm events
during the construction phase.   Best management practices
erosion controls should be installed early during the
construction period so as to prevent the transport of sediment
into surface waters which could result in water quality
violations and Departmental enforcement action.  Revegetation
and stabilization of disturbed areas should be accomplished as
soon as possible to reduce the potential for further soil
erosion.  Should construction phase runoff pose a threat to the
water quality of state waters,  additional measures such as
treatment of impounded runoff or by the use of turbidity
curtains (screens) in on-site impoundments .shall be immediately
implemented with any releases to state waters to be controlled.

          e.  It is necessary that there be an entity
responsible for maintenance of the system pursuant to Section
17-25.027, F.A.C.

          f .  Correctional action or modification of the system
will be necessary should mosquito problems occur.

          g.  CBC shall submit to DEP with copy to RESp and the
SJRWMD, erosion control plans for the entire construction
project (or discrete phases of the project) detailing measures
to be taken to prevent the off site discharge of turbid waters
during construction.  These plans must also be provided to the
construction contractor prior to the initiation of
construction.

          h.  All swale and retention basin side slopes shall
be seeded and mulched or sodded within thirty days following
their completion and a substantial vegetative cover must be
established within ninety days of seeding.

          8. Sanitary wastes from CBCP shall be collected and
routed for treatment to the SKC domestic wastewater treatment
plant.

          B.   Water Monitoring Programs

          1.  Necessity and extent of continuation of
monitoring programs may be nodif ied  in accordance with
Condition No. XXI, Modification of Conditions.

          2.  Chemical Stormwater Monitoring - The parameters
described in Condition III. A. shall  be monitored during
discharge as described in condition  III A. commencing with the
start of construction or operation of the  CFBs and reported
quarterly to the Northeast District  Office.

          3.  Coal, Ash, and Limestone Storage Areas

          a.   Runoff from the coal  pile,  ash  and lime  stone
storage areas shall be retained on-site during normal
operations up to the 50-year, 24-hour storm event.  Monitoring
                               15

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Modified 4/12/93
             PA 88-24A
of metals, such as iron, copper, zinc, mercury silver,  and
aluminum, shall be done once a month during any month when a
discharge occurs at OSNs 003 or 008.
          b.  Stormvater from the storage area runoff pond
shall be sampled the first time each month there is a discharge
to the cooling tower pretreatment system under the operating
conditions approved herein.  Samples shall be taken for 12
separate months and analyses performed as specified in
Condition 5 below.
          4.  The ground water levels shall be monitored
continuously at selected wells as approved by the SJRWMD.
Chemical analyses shall be made on samples from all monitored
wells identified in Condition IV.F. and IV.G. below.  The
location, frequency and selected chemical analyses shall be as
given in Condition IV.F and IV.G.  The ground water monitoring
program shall be implemented at least one year prior to
commercial operation of the CFBs.  The chemical analyses shall
be in accord with the latest edition of Standard Methods for
the Analysis of Water and Wastewater.  The data shall be
submitted within 30 days of collection/analysis to the SJRWMD.
          5.  The reclaimed water transferred to Seminole Kraft
for cooling tower make-up water shall be monitored for the
following parameters:
          Flow  (gallons per minute)
          pH  (standard units)
          Iron  (mg/L)
          Total Copper (ug/L)
          Zinc  (mg/L)
          Mercury  (ug/L)
          Silver (ug/L)
          Aluminum (mg/L)
          Cadmium  (ug/L)
          Arsenic  (ug/L)•
          Antimony (mg/L)
Continuous/Flow Meter
Weekly/Meter or Grab
Monthly/Grab
Monthly/Grab
Monthly/Grab
Monthly/Grab
Monthly/Grab
Monthly/Grab
Monthly/Grab
Monthly/Grab
Monthly/Grab
                              16

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Modified 4/12/93                                     PA 88-24A



XV.       GROUND WATER

          A.  Water Well Construction Permit

          Prior to the construction, modification,  or
abandonment of a production well for the SK paper mill,
Seminole Kraft must obtain a Water Well Construction Permit
from the SJRWMD pursuant to Chapter 40C-3, F.A.C. Construction,
modification, or abandonment of a production well will require
modification of the SK consumptive use permit when such
construction, modification or abandonment is other than that
specified and described on SK's consumptive use permit
application form.  The construction, modification, or
abandonment of a monitor well specified in Condition IV.H. will
require the prior approval of the Department.  All monitor
wells intended for use over thirty days must be noticed to RESD
prior to construction or change of status from temporary to
permanent.

          B.  Well Criteria, Tagging and Wellfield Operating
Plan

          Leaking or inoperative well casings, valves, or
controls must be repaired or replaced by  SK as required to
eliminate the leak or make the system fully operational.
Failure to make such repairs will be cause for deeming the well
abandoned in accordance with Chapter 17.21.02(5), F.A.C.,
Chapter 373.309, Florida Statutes and Chapter 366.301  (b), and
 .307  (a), Jacksonville ordinance Code.  Wells deemed abandoned
will require plugging according to  state  and local regulations.

          A SJRWMD-issued identification  tag must be
prominently displayed by SK at each SK withdrawal site by
permanently affixing such tag to the pump, headgate, valve or
other withdrawal facility as provided by  Section 40C-2.401,
Florida Administrative Code.  The SK must notify the SJTWMD  in
the event that  a replacement tag is needed.

          SK must  develop and implement a Wellfield  Operating
Program within  six (6) months after construction of  wells or
 start-up  of the CBCP.  This program must  describe which wells
 are primary,  secondary,  and standby (reserve); the  order  of
 preference  for  using  the wells; criteria  for shutting  down and
 restarting  wells;  describe CBCP and SKC responsibilities  in  the
 operation of the well field, and any  other  aspects  of  well
 field management operation,  such as who the well field operator
 is and any  other aspects of wellfield management operation.
 This program must be  submitted  to  the SJRWMD and a  copy to RESD
 within six  (6)  months of certification and  receive  SJRWMD   .
 approval  before the wells may be used to  supply  water for the
 Cedar Bay Cogeneration plant.
                               17

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Modified 4/12/93                      .               PA 88-24A
          C.  Maximum Annual Withdrawals

          CBCP's maximum annual use from the Floridan aquifer
may not exceed 530.7 million gallons.  Maximum daily use from
the Floridan aquifer for the CBCP may not exceed 1.45 million
gallons.  The use of potable water from the Floridan aquifer
for cooling purposes is prohibited.  The use of potable water
from the Floridan aquifer for control of fugitive dust
emissions is prohibited when alternative water sources are
available, such as treated wastewater, shallow aquifer wells or
stormwater.  The use of Floridan aquifer potable water for the
sole purpose of waste stream dilution is prohibited.

          D.   Water Use Transfer

          The SJRWMD must be notified, in writing, within 90
days of the transfer of this certification.  All transfers are
subject to the provisions of Section 40C-2.351, F.A.C., which
state that all terms and conditions of the permit shall be
binding of the transferee.

          £.   Emergency Shortages

          Nothing in this certification is to be construed to
limit the authority of the SJRWMD to declare a* water shortage
and issue orders pursuant to Section 373.175, Florida Statutes,
or to formulate a plan for implementation during periods of
water shortage, pursuant to Section 373.246, Florida Statutes.
In the event a water shortage, is declared by the District
Governing Board, the CBCP shall adhere to water shortage
restrictions as specified by SJRWMD to the extent the
restrictions apply to all other similar users.

          F.   Monitoring and Reporting

          l.a.   The permittee shall maintain records of total
daily use by the CBCP on a monthly basis for each year ending
on December 31st.  These records shall be submitted to the
SJRWMD on Form EN-3 by January 31st of each year.

          b.   Prior to beginning water usage, all points where
water is delivered from the SKC water supply or wastewater
system for use at CBCP must be equipped with totalizing flow
meters.  Such meters must maintain a 95% accuracy, be
verifiable and be installed according to the manufacturer's
specifications.

          c.   CBCP must maintain the required flow meter(s).
In case of failure or breakdown of any meter or other flow
measuring device, the SJRWMD must be notified in writing within
5 days of its discovery.  A defective meter must be repaired or
replaced within 30 days of its discovery.
                              18

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 Modified 4/12/93              .                       PA 88-24A
           d.    Total withdrawals from each monitored source
 must be recorded  continuously, totalled monthly, and reported
.to the  SJRWMD at  least  every six months from the initiation of
 the monitoring using SJRWMD Form No. EN-50.

           •.    CBCP must have all flow meters checked for
 accuracy once every 3 years within 30 days of the anniversary
 date of commencement of operation of the CBCP, and recalibrated
 if the  difference between the actual flow and the meter reading
 is greater than 5%.  SJRWMD Form No. EN-51 must be submitted to
 the SJRWMD within 10 days of meter inspection and calibration.

           2.    Water quality samples shall be taken by SK in
 May and October of each year from each SK .production well.  The
 samples shall be  analyzed by a DEP certified laboratory for the
 following parameters:

              Magnesium           Sulfate
              Sodium              Carbonate
              Potassium           Bi-Carbonate  (or alkalinity
                                 if pH is  6.9 or lower)
              Chloride            Calcium

 All major ion analyses  shall be checked for anion/cation
 balance and must  balance within 5 percent prior to submission.
 It is recommended that  duplicates be taken to allow for
 laboratory problems or  loss.  The sample analyses shall be
 submitted to  the  SJRWMD by May 30 and October 30 of each year.

           3.   Legal uses of water existing at the time of
 certification application may not be significantly adversely  .
 impacted by the consumptive use for the CBCP.  If unanticipated
 significant adverse impacts occur, the consumptive use shall be
 subject to modification in whole or in part to curtail or abate
 the adverse impacts, unless the impacts can be mitigated by
 CBCP.

           4.   Off-site  land uses existing at the time of
 certification application may not be significantly adversely
 impacted as a result of the consumptive use for the CBCP.  If
 unanticipated significant adverse impacts occur, the
 consumptive use shall be subject to revocation or modification
 in whole or in part to  curtail or abate the adverse impacts,
 unless  the impacts can  be mitigated by CBCP.

           5.   During the seventh year following issuance of
 this certification order, CBCP shall submit a report to SJRWMD,
 DEP, and RESD demonstrating compliance with these conditions of
 certification, Chapter- 373, Florida Statutes, and the Rules of
 SJRWMD  and DEP, applicable to the consumptive use of water.
 Compliance shall  be demonstrated with rules and statutory
 provisions in effect at that time.
                               19

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Modified 4/12/93                                     PA 88-24A
          SJRWMD shall evaluate the report and notify DEP in a
report of any issues regarding compliance with this
certification and applicable rules and statutory provisions,
including whether the consumptive use of vater for the CBCP
complies with those provisions of Chapter 272, Florida
Statutes, and DEP's and SJRWMD's rules applicable to its
consumptive use and whether any conditions of certification
oust be amended, added or deleted in order to insure that the
referenced rules and statutory provisions are complied with.
SJRWMD shall respond within 30 days of receipt of CBCP's report
as to whether or not it contains information sufficient to make
a determination as to compliance with the referenced rules and
statutory provisions.  Thereafter, DEP shall notify CBCP and
RESD within ninety (90) days after DEP's determination that
CBCP's report is sufficient.  Section 40C-1.610, F.A.C., shall
apply.  An opportunity for hearing pursuant to Section 120.57,
Florida Statutes, shall be afforded any party.  In any hearing
requested pursuant to this condition of certification, the
burden of demonstrating compliance shall be on CBCP.  The
continued consumptive use of water for the CBCP shall be
dependent upon CBCP demonstrating and presenting sufficient
data to establish that its consumptive use meets the referenced
rules or statutory provisions.  The Board hereby delegates to
the Secretary the authority to enter final orders regarding
this condition in the event an administrative hearing is
requested.

          G.   Ground Water Monitoring Requirements

          After consultation with the DEP, RESD, and SJRWMD,
CBCP shall install a monitoring well network to monitor ground
water quality horizontally and vertically through the aquifer
above the Hawthorn Formation.  Ground water quantity and flow
directions will be determined seasonally at the site through
the preparation of seasonal water table-contour maps, based
upon water level data obtained during the applicant's
preoperational monitoring program.  From these maps and the
results of the detailed subsurface investigation of site
stratigraphy, the water quality monitoring well network will be
located.  A ground water monitoring plan that meets the
requirements of Section 17-522.600(3), F.A.C., shall be
submitted to the Department's Northeast District Office for
review.  Approval or disapproval of the ground water monitoring
plan shall be given within 60 days of receipt.  Ground water
monitoring shall be required at CBCP's palletized ash storage
area, each sedimentation pond, and each coal pile storage area,
and SK's new lime mud storage area.  Insofar as possible, the
monitoring wells may be selected from the existing wells and
piezometers used in the permittees preoperational monitoring
program, provided that the wells construction will not preclude
their use.  Existing wells will be properly sealed in
accordance with Chapter 17-532, F.A.C., whenever they are
abandoned due to construction of facilities.  The water samples
collected from each of the monitor wells shall be collected
immediately after removal by pumping of a quantity of water



                                   6-47

                              20

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Modified 4/12/93                                     PA 88-24A
equal to at least three casing volumes.   The water quality
analyses shall be performed monthly during the year prior to
commercial operation and quarterly thereafter.  No sampling or
analysis is to be initiated until receipt of written approval
of a site-specific quality assurance project plan (QAPP by the
Department.  Results shall be submitted to the RESD and the DEP
NE District by the fifteenth (15th) day of the month following
the month during which such analyses were performed prior to
commercial operation, or by the 30th day of the month following
the calendar quarter such analyses were performed after start
of commercial operation.  Testing for the following
constituents is required around unlined ponds or storage areas:

     TDS                           cadmium-

     Conductance           '        Zinc

     pH                            Copper

     Redox                         Nickel    .  '

     Sulfate                       Selenium

     Sulfite                       Chromium

     Color                         Arsenic

     Chloride     .                 Beryllium

     Iron                          Mercury

     Aluminum            .          Lead

                                   Gross Alpha


          Conductivity  shall be monitored  in wells  arbund  all
 lined  solid waste disposal sites,  coal piles, and wastewater
 treatment and sedimentation ponds.

          H.   Leachate

           1.   Zone  of  Discharge

               Leachate from CBCP's  coal storage  piles,  SK's
 lime mud storage area or CBCP's sedimentation ponds shall  not
 cause  or contribute  to  contamination of waters  of the  State
 (including both  surface and ground waters)  in excess of  the
 limitations of Chapter  17-302, and 17-520,  F.A.C.,  beyond  the
 boundary of a zone of discharge extending  to  the  top of  the
 Hawthorn 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  storage pile,  landfill or  ponds,  or .rising to
 the boundary of  the  site,  as appropriate.
                               21

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Modified 4/12/93   .                       -PA 88-24A
          2.   Corrective Action

               When the ground water monitoring system shows a
potential for this facility to cause or contribute to a.
violation of the ground water quality standards of Chapter
17-520, F.A.C., at the boundary of the zone of discharge,  the
appropriate ponds 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 ground water standards will occur beyond the
boundary of the zone of discharge.

          I.   Water Use Audit

               At the end of the second year of production
withdrawals, CBCP must have conducted an audit of the amount of
water used in the various operational processes, landscaping
practices and domestic facilities.  If the audit results
indicate losses of water due to leakage, a leak detection
analysis must be conducted and submitted to the SJRWMD and a
leak repair program must be implemented.

          J.   Water Conservation Awareness Program

               Prior to beginning water usage, CBCP must
implement and submit to the SJRWMD an employee awareness
program (including such measures as posting signs regarding
water conservation and reporting leaks) concerning water
conservation.                                          <-—

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Modified 4/12/93                                     PA 88-24A



V.        CONTROL MEASURES DURING CONSTRUCTION

          A.   Storm Water Runoff

          During construction, appropriate measures shall be
used -to settle, filter, treat or absorb silt-containing or
pollutant- laden storm water runoff to limit the total
suspended solids to 50 mg/1 or less and pH to 6.0 to 9.0 at OSN
003 during rainfall events that are lesser in intensity than
the 10-year, 24-hour rainfall, and to prevent an increase in
turbidity of more than 29 NTU above background in waters of the
State.

          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 9.0 at OSN. 003.
Stormwater drainage to the Broward River shall be monitored as
indicated below:

Monitoring Point       Parameters     Frequency    Sample Type

* Storm water drainage   BODS, TOC, sus-      **           **
to the Broward River    pended solids,
from the runoff         turbidity, dis-
treatment pond          solved oxygen,
                        pH, TKN, Total
                        phosphorus ,
                        Fecal Coliform,
                        Total Colifonn
                        Oil and grease       **           **

        *Monitoring shall  be conducted at suitable points  for
allowing a  comparison  of  the  characteristics of preconstruction
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  at
least  ninety days prior to start of construction for review and
approval by the DEP  Northeast District Office.  The  District
Office will furnish  copies of the  sampling program to the RESD
and  SJRWMD  and shall indicate approval or  disapproval within  60
days of submittal.

          B.    Sanitary Wastes

                Disposal  of sanitary wastes from  construction
toilet facilities shall  be in accordance with applicable
regulations of the Department and  the RESD.

          C.    Environmental  Control Program

                CBCP  shall establish an  environmental control
program under  the supervision of a qualified person to assure
 that all  construction  activities conform  to  good environmental
                               23

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Modified 4/12/93                                     PA 88-24A
practices and the applicable conditions of certification.   A
written plan for controlling pollution during construction
shall be submitted to DEP and RESD within sixty days of
issuance of the Certification.  The plan shall identify.and
describe all pollutants and waste generated during
construction and the methods for control, treatment and
disposal.  CBCP shall notify the Department's Northeast
District Office and RESD by telephone within 24 hours if
 feasible if unexpected harmful effects or evidence of
 irreversible environmental damage are detected by it during
construction, shall immediately 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

               There shall be no discharge of construction
dewatering effluent,

VI.       8A7ETT

          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 construction 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 CBCP shall provide screening of the site to the
extent feasible through the 'use of aesthetically acceptable
structures, vegetated earthen walls and/or existing or planted
vegetation.

VTZZ.     TOXIC, DELETERIOUS, OK HAZARDOUS MATERIALS

          The spill of any toxic, deleterious, or hazardous
materials shall be reported in the manner specified by
Condition XI, Noncompliance Notification.

ZZ.       SOLID 1ABTB STORAGE AMD DISPOSAL

          CBCP shall be responsible for arranging for the
proper storage, handling, disposal, or reuse of any solid
waste generated by the CBCP facility.  Solid waste produced by
the operation of the CBCP facility shall be removed from site
and disposed of in a permitted disposal facility, with the
exception of bottom ash and fly ash.  Bottom ash and fly ash
will be pelletized, or made into aggregate form, and either  •

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Modified 4/12/93                                     PA 88-24A
shipped back to the nine utilizing the trains to deliver the
coal, or sold as an additive to concrete,  or utilized by
companies specializing in the marketing and utilization of
combustion by-products.  The bottom ash and fly ash shall not
i>e disposed of in a landfill within Duval County.  If the CBCP
decides to dispose of the bottom ash or fly ash by other than
returning it to the mine, they shall notify RESD and DEP.
Prior to removal and disposal of spent lime mud and pond
tailings, the CBCP shall determine whether those wastes are
hazardous under 40 CFR 26 and 17-730, F.A.C.  If wastes are
determined to be hazardous, they shall be disposed of in
accordance with Chapter 17-730, F.A.C., after consultation
with the DEP and RESD.  If not hazardous,  disposal shall be to
a landfill designed to ensure compliance with groundwater
quality criteria as contained in Chapters 17-3, and 17-730
F.A.C.  All solid wastes disposed of on site shall comply with
the provisions of Chapter 17-701, F.A.C.  Ground water
monitoring in accordance with 17-4, and 17-520, F.A.C. shall
be implemented at the lime mud disposal site.

          At least ninety  (90) days prior to disposal or use
of any sludge generated by pretreatment of reclaimed Seminole
Kraft wastewater or zero wastewater discharge system, CBCP
shall report to DEP and RESD concerning the chemical
characterization of any such sludge.  DEP reserves the right
to require additional sampling and analysis as necessary to
ensure that the above-cited regulations are complied with.
Prior to any such sludge disposal, CBCP shall obtain a letter
of acceptance from a permitted disposal site.  On or before
the last day of the first year of commercial operation, and
each year of commercial operation thereafter, CBCP shall
report to DEP and RESD concerning the composition and quantity
of sludge generated by the zero water discharge system and the
method of disposal, including name and location of facilities
handling, treating, storing, and/or disposing of said sludge
waste.
                   »

X.        CEAMGE IN DISCHARGE

          All discharges or emissions authorized herein to
CBCP shall be consistent with the terms and conditions of this
certification.  The discharge of any pollutant not identified
in the application or any discharge more frequent than, or at
a level  in excess of, that authorized herein shall constitute
a violation of this certification.  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 to DEP's Siting
Coordination Office pursuant to Chapter 403, F.S.
                                      6-52-
                               25

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Modified 4/12/93                                     PA 88-24A
ZZ.       KOHCOKFLZAKCB NOTIFICATION

          If, for any reason, either permittee does not comply
with or will be unable to comply with any limitation specified
in this certification, the permittee shall notify the DEP's
Northeast District Office and RESD office by telephone as soon
as possible but not later than the first DEP working day after
the permittee becomes aware of said noncompliance, and shall
confirm the reported situation in writing within seventy-two
(72) hours supplying the following information:

          A.  A description and cause of noncompliance; and

          B.  The period of noncompliance, -including exact
dates and times; or, if not corrected, the anticipated time
the noncompliance is expected to continue, and steps being
taken to reduce, eliminate, and prevent recurrence of the
noncomplying event.

ZZZ.      FACZLZTZE8 OPERATION

          Each permittee shall at all times maintain in good
working order and operate as efficiently as possible all of
its treatment or control facilities or systems 'installed or
used by the permittee to achieve compliance with the terms and
conditions of this certification.  Such systems are not to be
bypassed without prior Department (Northeast District)
approval and after notice.to RESD except where otherwise
authorized by applicable regulations.

ZZZZ.     ADVERSE IKPACT

          Each permittee shall take all reasonable steps to
minimize any adverse impact resulting from its noncompliance
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 noncomplying event.

ZZY.      RIGHT 07 ENTRY

          The permittees shall allow the Secretary of the
Florida Department of Environmental Protection and/or
authorized DEP representatives, and representatives of the
RESD and SJRWMD, upon the presentation of credentials:  •

          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
monitoring method required in this certification and to sample
any discharge or emissional pollutants; and



                                    6-53
                              26

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Modified 4/12/93                                     PA 88.-24A
          D.   To assess any damage to the environment or
violation of ambient standards.

          E.  SJRWMD authorized staff, upon proper
identification, will have permission to enter,  inspect, and
observe permitted and related CBCP facilities in order to
determine compliance with the approved plans, specifications,
and conditions of this certification.

          F.  RESD authorized staff, upon proper
identification, will have permission to enter,  inspect, sample
any discharge, and observe permitted and related facilities in
order to determine compliance with the approved plans,
specifications, and conditions of this certification.

XV.       REVOCATIOH OR SUSPENSION

          This certification may be suspended,  or revoked
pursuant to Section 403.512, Florida Statutes,  or for
violations of any Condition of Certification.

XVI.      CZVZL AND CRZXZNAL LIABILITY

          This certification does not relieve either permittee
from civil or criminal responsibility or liability for
noncompliance with any conditions of this certification,
applicable rules or regulations of the Department, or Chapter
403, Florida Statutes, or regulations thereunder.

          Subject to Section 403.511, Florida Statutes, this
certification shall not preclude the  institution of any legal
action or relieve either permittee from any  responsibilities
or penalties established pursuant to  any other applicable
State Statutes or regulations.

XVII.     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 permittees shall
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.

XVIII.    SEVERABXLXTY

          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.
                               27

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Modified 4/12/93                    •                 PA 88-24A
ZVZV.     DEFINITIONS

          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 conditions which is not defined in such statutes or
regulations, such dispute shall be resolved by reference to
the most relevant definitions 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.

ZZ.       REVIEW OF BITS CERTIFICATION

          A.  The certification shall be final unless revised,
revoked, or suspended pursuant to lav.  At least every five
years from the date of issuance of this certification or any
National Pollutant Discharge Elimination Control Act
Amendments of 1972 for the plant units, the Department shall
review all monitoring data that has been submitted to it or
it's agent(s) during the preceding 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
permittees.  Such review will be repeated at least every five
years thereafter.

ZZI.      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,
reclaimed water, monitoring, sampling, ground water, surface
water, mixing zones, or variances to water quality standards,
zones of discharge, leachate control programs, effluent
limitations, air emission limitations, fuel, or solid waste
disposal, right of entry, railroad spur transmission line,
access road, pipelines, or designation of agents for the
purpose of enforcing the conditions of this certification.

          B.  All other modifications shall be made in
accordance with Section 403.516,  Florida Statutes.

XIII.     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.

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Modified 4/12/93           •                          PA 8B-24A
ZZZZZ.    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, modified, or as the Department and
parties .are otherwise notified, is binding upon the applicants
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.

ZXZV.     VOZ8B

          To mitigate the effects of noise produced by the
steam blowout of steam boiler tubes, each permittee shall
conduct public awareness campaigns prior to such activities to
forewarn the public of the estimated time and duration of the
noise.  The permittees shall comply with the applicable noise
limitations specified in Environmental Protection Board Rules
or The City of Jacksonville Noise Ordinance.

ZZV.      UBS OF HATER FOR COOLING PURPOSES

          The CBCP shall use reclaimed wastewater from the
Seminole Kraft paper mill  (in addition to any wastewater
generated by the CBCP that is suitable for reuse for that
purpose) for cooling water supply.  In the event of disruption
of SKC reclaimed wastewater «s the cooling water makeup source
for Cedar Bay, Inc., Cedar Bay, Inc. will utilize the water
retained in SKC's holding basins or other non-potable sources
of water as cooling water makeup.

        in At least 90 days prior to beginning commercial
operation, Cedar Bay Cogeneration, Inc.- shall, submit- to the  -
Department a report concerning the actual measured pollutant
characteristics of reclaimed water to be obtained from the
Seminole Kraft paper mill.  Such report shall be based on
approved analytical results from four monthly samples obtained
directly from the Seminole Kraft waste stream to be tied in
with  the CBCP cooling system, and shall include the
concentrations of BODS, COD, total organic carbon, total
suspended solids, ammonia, pH, oil and grease, calcium,
magnesium, sodium, potassium, alkalinity as mg of CaCO3,
sulfate, chloride, nitrate, fluoride, silica, chlorine,
phosphate  (total) as P, cyanide, iron, manganese, aluminum,
nickel, zinc, copper, cadmium, chromium, beryllium, arsenic,
selenium, antimony, mercury, barium, silver, lead, thallium,
phosphorus, and TKN.  Where applicable, wastewater sampling
and analyses conducted by  SKC under the terms of operation
permit  number 1016-200147  may be used to meet the terms of
this  condition.  Any other sampling and analyses submitted
under the terms of this permit shall be in accordance with a
Department-approved Quality Assurance Plan.  Results of all
testing and sampling specified above shall be  submitted to the
Department within  30 days  of testing.
                               29

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Modified 4/12/93                                     PA 88-24A
          Seminole Kraft's generation, treatment, or discharge
 of its vastewater is not covered by this site certification,
 and the permitting of Seminole Kraft's generation, treatment,
 or discharge  of  its vastevater does not require Siting Board
 approval.

 XXVI.     EN70RCEXENT

          A.  The Secretary may take any and all lawful
 actions as  he or she deems appropriate to enforce any
 condition of  this certification.

          B.  Any participating agency (federal, state, local)
 may take any  and all lawful actions to enforce any condition
 of this certification that is based on the rules of that
 agency.  Prior to initiating such action the agency head shall
 notify the  Secretary of that agency's proposed action.

          C.  RESD may initiate any and all lawful actions to
 enforce the conditions of this certification that are based on
 the Department's rules> after obtaining the Secretary's
 written permission to so process on behalf of the Department.

 XXVII.    ENDANGERED AND THREATENED SPECIES

          Prior  to start of construction, CBCP shall survey
 the site for  endangered and threatened species of animal and
 plant life.  Plant species on the endangered or threatened
 list shall  be transplanted to an appropriate area if
 practicable.  Gopher Tortoises and any commensals on the rare
 or endangered species  list shall be relocated after
 consultation  with the Florida Came and Fresh Water Fish
 Commission.  A relocation program, as approved by the FGFWFC,
 shall be followed.

 XXVIII.   ENVIRONMENTALLY SENSITIVE LAND ACQUISITION

          a.   Periodic Payments

          1.   As a condition of this certification, CBCP
 shall be required to make periodic monetary contributions for
 the purpose of funding a program for the acquisition and
 management  of environmentally sensitive lands in Duval County,
 Florida.  These  payments shall be made to The Nature
 Conservancy,  Inc.,  in trust for the State of Florida, to be
 used as provided in Section B below;  and to the City of
 Jacksonville  Environmental Land Acquisition Trust Fund, to be
 used as provided in Section C below.

          2.   The two million dollar payment made by or on
 behalf of the AES Corporation to The Nature Conservancy,  •
 Inc.,(TNC)  on or about June 16, 1992, shall be deemed to be
 the first of  two periodic payments, totaling 4.5 million
 dollars,  which  the CBCP is obligated to make to TNC under
 this condition.  The second periodic payment, 2.5 million
'dollars, shall be transmitted within 48 hours of  the date on
                                •


                                   6-57

                              30

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Modified 4/12/93                                     PA 88-24A
which the CBCP commences commercial operation.  TNC shall hold
all funds received from CBCP or on behalf of CBCP in trust for
the State of Florida.
          3.   Commencing on the anniversary of the second
payment required by subsection (2) above, and continuing each
year for 30 years thereafter, a payment of $300,000 shall be
submitted to the City of Jacksonville for each year that the
CBCP remains in commercial operation.  Each annual payment
shall be transmitted within 48 hours of the anniversary of the
date on which commercial operation commenced at CBCP,  and
shall be deposited in the Jacksonville Environmental Land
Acquisition Trust Fund (JELATF) established by S 110.362 of
the Jacksonville Ordinance Code.

          4.   Any failure to achieve timely transmission of a
periodic payment required by this condition shall be grounds
for revocation of the certification.

          5.   All funds attributable to the periodic payments
required by this condition shall be received, held, disbursed,
and expended in conformance with the applicable provisions of
this Condition.

          6.   The express intent of this Condition is to
assure that these periodic payments fund the acquisition of
lands possessing substantial ecological value to the ecosystem
of the St. Johns River watershed; and that lands acquired with
funds provided under this condition be managed to retain or
enhance the ecological values for which they were acquired.
Funds made available under this Condition shall not be used
for the development of urban recreational facilities which
conflict with the natural resource values of a site.
Prohibited facilities include ball fields or courts,
playgrounds, and other developed amenities which are not
dependent on ecological conditions for their existence and
which are not ancillary to public access for recreational
enjoyment of the available natural resources.

          7.   Properly managed natural resource-based
recreation which does not degrade the ecological values of a
site shall be encouraged through the development of
appropriate management plans which shall be approved by the
Department for any tract purchased under this Condition.
Management of any site shall be consistent with the
acquisition criteria specified in this Condition and shall be
coordinated with other managers of natural lands in the
region, such as the Department, the St. Johns River Water
Management District, the National Park Service, the Division
of Forestry, and the Florida Game and Fresh Water Fish
Commission.

          8.   Funds aade available under this Condition nay
be used to participate in existing public and private
environmental land acquisition programs such as the
Conservation and Recreational Lands Program (CARL) , Save Our
Rivers (SOR) , Florida Communities Trust (FCT) , Land
                              31

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Modified 4/12/93                                     PA 88-24A
Acquisition Trust Fund (LATF), Preservation 2000, The Nature
Conservancy, and other similar programs consistent with the
intent behind this condition.

          b.   Land Acquisition Process:  State of Florida

          1.   All land acquisition and management activities
funded by the certification for the use and benefit of the
State of Florida or its designee shall be undertaken in
accordance with the process established by this Section.

          2.   The Nature Conservancy (TNC) shall serve as the
agent for acquisition of any parcel of land purchased with
funds made available under this condition.. The Department and
TNC shall enter into an -agreement which incorporates the
provisions of this Condition and such other provisions not
inconsistent with this Condition that the Department finds
necessary to assure that this Section is properly implemented
in the public interest. The agreement shall specify the duties
and responsibilities of the parties with respect to the
retention and disbursement of funds received to assure an
accurate accounting and audit trail.

          3.   There shall be a six member Land Acquisition
and Management Advisory Council (LAMAC) comprising two
representatives appointed by each of the following
governmental entities:  the Department, the St. Johns River
Water Management District, and the City of Jacksonville.  TNC
shall appoint a representative to serve as chair of the LAMAC.
The LAMAC shall hold one or more public hearings for the
purpose of receiving public input as to lands potentially
suitable for acquisition under this Section.  Following
appropriate public input, the LAMAC shall report its findings
to the Department.

          4.   After review of the LAMAC report, TNC shall
identify and list as many land acquisition options as it deems
practicable.  A copy of the list shall be submit-ted to each of
the entities represented on the LAMAC.  In establishing this
list, TNC shall consider:

          a.   the regional environmental importance of each
parcel of property, taking into account its proximity to water
bodies and other publicly-held land;

          b.   the extent of wildlife habitat and diversity on
each parcel and the effect of its acquisition on regional
efforts towards wildlife conservation; and

          c.   the potential of each parcel for environmental
enhancement, restoration, and natural resource-based
recreational uses.

The LAMAC shall review and approve the land acquisition
options list before any parcels are acquired under this
condition.

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 Modified 4/12/93                                     PA 88-24A
           5.    Following approval of the list, TNC shall
 initiate  selection of parcels to be acquired.  In selecting
 parcels for acquisition, preference shall be given to parcels
 located near  the CBCP site, including parcels within or
 adjacent  to the Timucuan Ecological and Historical Preserve
 managed by the  National Park Service.  Preference shall also
 be  given  to the selection of larger parcels which can be
.purchased using contributions from other entities to
 supplement funds available under this condition.  After
 approval  by the Secretary of the Department of a proposed
 acquisition,  the parcel shall be purchased by TNC in trust for
 the State of  Florida.

           6.    Title to any parcel purchased under this
 condition shall-ultimately vest in a governmental entity
 following a determination by the Secretary of the Department,
 after consultation with the LAMAC, as to how the property can
 be  managed most appropriately in the public interest.  It is
 understood that title to a newly-purchased parcel may
 initially vest  in TNC pending this determination and transfer
 of  the title  to an appropriate government entity or entities
 for management.  The Siting Board hereby delegates to the
 Secretary of  the Department the authority to select the
 governmental  entity or entities most suitable to hold title
 and manage any  property purchased under this condition.  Upon
 notification  from the Department that the selection has
 occurred,  TNC shall forthwith execute a transfer of title to
 the designated  entity or entities.

           7.    TNC shall be entitled to receive reimbursement
 from funds held by it under this Condition for any costs
 related to the  performance of an acquisition under this
 Section.   TNC may expend on an annual basis up to two per cent
 of  the purchase price of a parcel to which it holds interim
 title to  defray expenses associated with management of that
 parcel until  title can be transferred as specified in
 subsection (6).

           8.    TNC is hereby authorized to explore and enter
 into financing  arrangements which will allow the expected
 proceeds  of the periodic payments required under this
 condition to  be capitalized for immediate utilization in land
 acquisition or  for appropriate installment payments in the
 event that it is possible to defer full payment for a parcel
 over a number of years.  CBCP shall cooperate to the maximum
 extent in assisting TNC to achieve such alternate financing
 arrangements  for the benefit of the public as may be
 practicable.

         .  c.    Land Acquisition Process:  City of Jacksonville

           1.    All land acquisition and management activities
 funded by Section A.3 of this Condition for the use and
 benefit of the  City of Jacksonville or its designee shall be
 undertaken in accordance with the process established by this
 Section.
                              33

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Modified 4/12/93                                     PA 88-24A
          2.   The Real Estate Division of the City of
Jacksonville Public Works Department or another appropriate
governmental entity shall serve as the agent for acquisition
of any parcel of land purchased with funds made available
under this Condition.  The Department and the City of
Jacksonville shall enter into an agreement which incorporates
the provisions of this Condition and such other provisions not
inconsistent with this Condition that the Department finds
necessary to assure that this Section is properly implemented
in the public interest. The agreement shall specify the duties
and responsibilities of the parties with respect to the
retention and disbursement of funds received to assure an
accurate accounting and audit trail.

          3.   The City of Jacksonville, acting through the
Jacksonville Environmental Land Selection Committee (JELSC)
established by Mayoral Executive Order 85-81, as amended by
Executive Order 91-147, pursuant to S 110.362 of the
Jacksonville Ordinance Code, shall identify and list as many
land acquisition options as it deems practicable.  In
establishing its list, JELSC shall consider:

          a.   the regional environmental importance of each
parcel of property, taking into account its proximity to water
bodies and other publicly-held land;

          b.   the extent of wildlife habitat and diversity on
each parcel and the effect of its acquisition on regional
efforts towards wildlife conservation; and

          c.   the potential of each parcel for environmental
enhancement, restoration, and natural resource-based
recreational uses.

          d.   the goals, objectives, and policies of the
Conservation/Coastal Management element of the City's
Comprehensive Plan, as amended.

          A copy of the JELSC list, as it may be amended from
time to time, shall be supplied to the Department and to the
St. Johns River Water Management District. JELSC shall furnish
a copy of the list upon its initial preparation and after any
subsequent amendment thereto.

          4.   Lands to be acquired under this Section with
funds made available in whole or in part under this Condition
may be acquired only with the concurrence of the Jacksonville
City Council and the Department.  In selecting parcels for
acquisition, preference shall be given to parcels located near
the CBCP site,  including parcels within or adjacent to the
Timucuan Ecological and Historical Preserve managed by the
National Park Service.  Preference shall also be given to the
selection of larger parcels which can be purchased using con-
tributions from other entities to supplement funds available
under this condition.  After approval by the Department and
the City Council of a proposed acquisition, the parcel shall
be purchased by the City.

                                         6-61

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Modified 4/12/93                                     PA 88-24A
         '5.   With the approval of the Department and the
City Council, title to land acquired under this Section may be
sold or transferred to a governmental entity to facilitate
effective and beneficial management of the parcel.  Any funds
received by the City as a result of sale or transfer of
property previously acquired under this Section shall be
deposited in the JELATF and remain subject to the provisions
of this.Condition.

          6.   Any funds paid by CBCP to the JELATF in
fulfillment of this Condition or in accordance with any other
Condition of Certification may be used for the purpose of
managing lands acquired under this Section.-

          7.   The City of Jacksonville is hereby authorized
to explore and enter into financing arrangements which will
allow the expected proceeds of the periodic payments available
under this Section to be capitalized for immediate utilization
in land acquisition and management or for appropriate
installment payments in the event that it is possible to defer
full payment for a parcel over a number of years.  CBCP shall
cooperate to the maximum extent in assisting the City to
achieve such alternate financing arrangements for the benefit
of the public as may be practicable.

          8.   Sale or transfer of any parcel acquired under
this Section shall be subject to a reversionary interest
retained by the Board of Trustees of the Internal Improvement
Trust Fund.  In the event that the property ever ceases to be
used and managed for environmental purposes consistent with
this Condition, ownership of the property shall immediately
revert to the State of Florida.

ZZZZ.     TRANSFER OF CERTIFICATION

          If the Cedar Bay Cogeneration Project is sold or
legally transferred to another owner, notice of such sale or
transfer shall immediately be submitted to the Florida
Department of Environmental Protection and the agency parties
to this certification by the previous certification holder
 (permittee) and the assignee.  Included in the notice shall be
the identification of the entity responsible for compliance
with the Certification.  Any assignment or transfer shall
carry with  it the full responsibility for the limitations and
conditions  of this Certification.         .
                               35

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      SETTLEMENT STIPULATION
                  *
           ATTACHMENT C

CONDITION OF CERTIFICATION  XXVIII

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                          ATTACHMENT C

XXVIII    Environmentally Sensitive Land Acquisistion

A.  Periodic Payments

1.  As a condition of this certification, CBCP shall be required
to make periodic monetary contributions for the purpose of
funding a program for the acquisition and management of
environmentally sensitive lands in Duval County, Florida.   These
payments shall be made to The Nature Conservancy, Inc., in trust
for the State of Florida, to be used as provided in Section B
below;  and to the City of Jacksonville Environmental Land
Acquisition Trust Fund, to be used as provided in Section C
below.

2.  The two million dollar payment made by or on behalf of the
AES Corporation to The Nature Conservancy, Inc.,(TNC) on or about
June 16, 1992, shall be deemed to be the first of two periodic
payments, totalling 4.5 million dollars,  which the CBCP is
obligated to make to TNC under this condition.  The second
periodic payment, 2.5 million dollars, shall be transmitted
within 48 hours of the date on which the CBCP commences
commercial operation.  TNC shall hold all funds received from
CBCP or on behalf of CBCP in trust for the-State of Florida.

3.  Commencing on the anniversary of the second payment required
by subsection (2) above, and continuing each year for 30 years
thereafter, a payment of $300,000 shall be submitted to the City
of Jacksonville for each year that the CBCP remains in commercial
operation.  Each annual payment shall be transmitted within 48
hours of the anniversary of the date on which commercial
operation commenced at CBCP, and shall be deposited in the
Jacksonville Environmental Land Acquisition Trust Fund (JELATF)
established by $ 110.362 of the Jacksonville Ordinance Code.

4.  Any failure to achieve timely transmission  of a periodic
payment required by this condition shall be grounds for
revocation of the certification.

5.  All funds attributable to the periodic payments required by
this condition shall be received, held, disbursed, and expended
in conformance with the applicable provisions of this Condition.

6.   The express intent of this Condition is to  assure that these
periodic payments fund the.acquisition of lands  possessing
substantial ecological value to the ecosystem of the St. Johns
River watershed; and that lands acquired with funds provided
under -this condition be managed to retain or enhance the
ecological values for which they were acquired.  Funds made
available under this Condition shall not be used for the
development of urban recreational facilities which conflict with
the natural resource values of a site.  Prohibited facilities
include ball fields or courts, playgrounds, and other developed
amenities which are not dependent on ecological conditions  for
their existence and which are not ancillary to  public access for

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recreational enjoyment of the available natural resources.
             ^.
7   Properly managed natural resource-based recreation which does
not degrade the ecological values of a site shall be encouraged
through the develoment of appropriate management plans which
shall be approved by the Department for any tract purchased under
this Condition.  Management of any site shall be consistent with
the acquisition criteria specified in this Condition and shall be
coordinated with other managers of natural lands in the region,
such as the Department, the St. Johns River Water Management
District, the National Park Service, the Division of Forestry,
and the Florida Game and Fresh Water Fish Commission .

8.  Funds made available under this Condition may be used to
participate in existing public and private environmental land
acquisition programs such as the Conservation and Recreational
Lands Program  (CARL), Save Our Rivers  (SOR), Florida Communities
Trust (FCT), Land Acquisition Trust Fund  (LATF), Preservation
2000, The Nature Conservancy, and other similar programs
consistent with the intent behind this condition.

B.  Land Acquisition Process:  State of Florida

1.  All land acquisition and management activities funded by the
certification  for the use and benefit  of the State of Florida or
its designee shall be undertaken in accordance with the process
established by this Section.

2.  The Nature Conservancy  (TNC) shall serve as the agent for
acquisition of any parcel of land purchased with funds made
available under this condition.  The Department and TNC shall
enter into an  agreement which incorporates the provisions of this
Condition and  such other provisions not inconsistent with this
Condition that the Department finds necessary to assure that this
Section is properly implemented  in the public interest. The
agreement shall specify the duties, and-responsibilities.of the
parties with respect to the retention  and disbursement of funds
received to assure an accurate accounting and audit trail.

3.  There shall be a six member  Land Acquisition and Management
Advisory Council  (LAMAC) comprising two representatives appointed
by each of the following governmental  entities:  the Department,
the St. Johns  River Water Management District, and the City of
Jacksonville.  TNC shall appoint a representative to serve as
chair of the LAMAC.  The LAMAC shall hold one or more public
hearings for the purpose of receiving  public input as to lands
potentially suitable for acquisition under this Section.
Following appropriate public input, the LAMAC shall report its
findings to the Department.

4.  After review of the LAMAC report,  TNC shall identify and  list
as many  land acquisition options as it deems practicable.  A  copy
of the  list shall be submitted to each of the entities
represented on the LAMAC.   In establishing this list, TNC shall
consider:

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    a.  the regional environmental importance of each parcel of
property, taking into account its proximity to water bodies and
other publicly-held land;

    b.  the extent of wildlife habitat and diversity on each
parcel and the effect of its acquisition on regional efforts
towards wildlife conservation; and

    c.  the potential of each parcel for environmental
enhancement, restoration, and natural resource-based recreational
uses.

The LAMAC shall review and approve the land acquisition options
list before any parcels are acquired under this condition.

5.  Following approval of the list, TNC shall initiate selection
of parcels to be acquired.  In selecting parcels for acquisition,
preference shall be given to parcels located near the CBCP site,
including parcels within or adjacent to the Timucuan Ecological
and Historical Preserve managed by the National Park Service.
Preference shall also be given to the selection of larger parcels
which can be purchased using contributions from other entities to
supplement funds available under this condition.  After approval
by the Secretary of the Department of a proposed acquisition, the
parcel shall be purchased by TNC in trust for the State of
Florida.

6.  Title to any parcel purchased under this condition shall
ultimately vest in a governmental entity following a
determination by the Secretary of the Department, after
consultation with the LAMAC, as to how the property can be
managed most appropriately in the public interest.  It is
understood that title to a newly-purchased parcel may initially
vest in TNC pending this determination and transfer of the title
to an appropriate government entity or entities for management.
The Siting Board hereby delegates to the Secretary of the
Department the authority to select the governmental entity or
entities roost suitable to hold title and manage any property
purchased under this condition.  Upon notification from the
Department that the selection has occurred, TNC shall forthwith
execute a transfer of title to the designated entity or entities.

7.  TNC shall be entitled to receive reimbursement from funds
held by it under this Condition for any costs related to the
performance of an acquisition under this Section.  TNC nay expend
on an annual basis up to two per cent of the purchase price, of a
parcel to which it holds interim title to defray expenses
associated with management of that parcel until title can be
transferred as specified in subsection  (6).

8.  TNC is hereby authorized to explore and enter into financing
arrangements which will allow the expected proceeds of the
periodic payments required under this condition to be capitalized
for immediate utilization in land acquisition or for appropriate
installment payments in the event that  it  is possible to defer
full payment for a parcel over a number of years.  CBCP shall
                                6

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cooperate to the maximum extent in assisting TNC to achieve such
alternate financing arrangements for the benefit of the public as
may be practicable.

C. Land Acquisition Process:  City of Jacksonville

1.  All land acquisition and management activities funded by
Section A.3 of this Condition for the use and benefit of the City
of Jacksonville or its designee shall be undertaken in accordance
with the process established by this Section.

2.  The Real Estate Division of the City of Jacksonville Public
Works Department or another appropriate governmental entity shall
serve as the agent for acquisition of any parcel of land
purchased with funds made available under this Condition.  The
Department and the City of Jacksonville shall enter into an
agreement which incorporates the provisions of this Condition and
such other provisions not inconsistent with this Condition that
the Department finds necessary to. assure that this Section is
properly implemented in the public interest. The agreement shall
specify the duties and responsibilities of the parties with
respect to the retention and disbursement of funds received to
assure an accurate accounting and audit trail.

3.  The City of Jacksonville, acting through the Jacksonville
Environmental Land Selection Committee (JELSC) established by
Mayoral Executive Order 85-81, as amended by Executive Order
91-147, pursuant to $ 110.362 of the Jacksonville Ordinance Code,
shall identify and list as many land acquisition options as it
deems practicable.  In establishing its list, JELSC shall
consider:

    a.  the regional environmental importance of each parcel of
property, taking into account its proximity to water bodies and
other publicly-held land;

    b.  the extent of wildlife habitat and diversity on each  •
parcel and the effect of its acquisition on regional efforts
towards wildlife conservation; and

    c.  the potential of each parcel for environmental
enhancement, restoration, and natural resource-based recreational
uses.

    d.  the goals, objectives, and policies of the
Conservation/Coastal Management element of the City's
Comprehensive Plan, as amended.               •

A copy of the JELSC list, as it may be amended from time to time,
shall be supplied to the Department and to the St. Johns River
Water Management District. JELSC shall furnish a copy of the list
upon its initial preparation and after any subsequent amendment
thereto.

4.  Lands to be acquired under this Section with funds made
available in whole or in part under this Condition may be

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 acquired only with the concurrence  of  the Jacksonville City
 Council and the Department.   In  selecting parcels  for
 acquisition,  preference shall be given to parcels  located near
 the CBCP site,  including parcels within  or adjacent to the
.Timucuan Ecological and Historical  Preserve managed by the
 National Park Service.   Preference  shall also be given to' the
 selection of larger parcels which can  be purchased using
.contributions from other, entities to supplement funds available
;under this condition.   After  approval  by the Department and the
 City Council of a proposed acquisition,  the parcel shall be
:purchased by the City.

 5.   With the approval  of the  Department  and the City Council,
 title to land acquired under  this Section may be sold or
 transferred to a governmental entity to  facilitate effective and
 beneficial management  of the  parcel.   Any funds received by the
 City as a result of sale or transfer of  property previously
 acquired under this Section shall be deposited in  the JELATF and
 remain subject tp the  provisions of this Condition.

 6.   Any funds paid by  CBCP to the JELATF in fulfillment of this
 Condition or in accordance with  any other Condition of
 Certification may be used for the purpose of managing lands
 acquired under this Section.

 7.   The City of Jacksonville  is  hereby authorized  to explore and
 enter into financing arrangements which  will allow, the expected
 proceeds of the periodic payments available under  this Section to
 be  capitalized for immediate  utilization in land acquisition and
 management or for appropriate installment payments in the event
 that it is possible to defer  full payment for a parcel over a
 number of years.   CBCP shall  cooperate to the maximum extent in
 assisting the City to  achieve such  alternate financing
 arrangements for the benefit  of  the public as may  be practicable.

 8.   Sale or transfer of any parcel  acquired under  this Section
 shall be subject to a  reversionary  interest retained by the Board
 of  Trustees of the Internal Improvement  Trust Fund	In the event
 that the property ever ceases to be used and managed for
 environmental purposes consistent with this Condition, ownership
 of  the property shall  immediately revert to the State of Florida.

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          SETTLEMENT STIPULATION  .



                ATTACHMENT D




SITE PLAN FOR CEDAR BAY COGENBRATXON PROJECT

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                               ATTACHMENT D
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           APPENDIX C

       EXECUTIVE SUMMARY
ENVIRONMENTAL IMPACT STATEMENT/
      STATE ANALYSIS REPORT
 CEDAR BAY COGENERATION PROJECT
            MAY 1990

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                        EXECUTIVE SUMMARY

                  ENVIRONMENTAL IMPACT STATEMENT
                    AND STATE ANALYSIS REPORT
                  Cedar Bay Cogeneration Project
                   AES/Cedar Bay/ Incorporated
                      Jacksonville, Florida
(X) Draft
( ) Final
         U.S. Environmental Protection Agency, Region IV
                     345  Courtland Street,  NE
                     Atlanta, Georgia  30365


          Florida Department of  Environmental  Regulation
                    Power Plant  Siting Section
                      2600 Blair Stone Road
                   Tallahassee,  Florida  32301


1.  Type of Action:            Administrative (X)
Legislative  ( )

2.  Description of Action

Applied Energy Services/Cedar Bay, Inc. (AES-CB) proposes to
construct and operate a new source cogeneration facility known
as the Cedar Bay Cogeneration Project  (CBCP).   This facility
will consist of three circulating fluidized bed (CFB) boilers
which will produce 225 megawatts  (MW) of electricity for sale to
Florida Power and Light Company (FPL) and 640-, 000 pounds per
hour of process steam for sale to the Seminole Kraft (SK) paper
mill.  These facilities will be located on a 35 acre site
adjacent to the existing SK paper mill in northern Duval County,
Florida.  AES-CB has applied to the U.S. Environmental
Protection Agency (USEPA) and the Florida Department of
Environmental Regulation  (FDER)  for permits necessary to operate
and construct the proposed facility.

This joint document has been 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 USEPA Region IV Administrator has determined that CBCP
discharges of wastewater from construction and operation will be
a New Source as defined by Section 306 of the Clean Water Act.
The CBCP will require a National Pollutant Discharge Elimination
System (NPDES) Permit.  Issuance of this Permit would be a major
Federal action significantly affecting the quality of the human
environment and subject to the provisions of NEPA.

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Consequently, the USEPA decided that an Environmental Impact
Statement (EIS) should be prepared.  Because under the Power
Plant Siting Act FDER is required to prepare a State Analysis
Report (SAR) containing information similar to that required in
an EIS/ USEPA and FDER have entered into a Memorandum of
Understanding agreeing to prepare a single document.  This joint
document, referred to as the SAR/EIS, will meet the
responsibilities of both agencies.

The determination of need for a new steam electric generating
facility in Florida is the responsibility of the Florida Public
Service Commission (FPSC).  On June 30, 1989, the FPSC granted
AES-CB and SK their petition for Determination of Need in the
FPSC Order No. 21491.  The order stated that the CBCP was a
qualifying facility pursuant to the Public Utility Regulatory
Policies Act of 1978 (PURPA) regulations and that AES-CB has
negotiated a contract with FPL for the sale of capacity and
energy at less than the statewide avoided cost.  This being the
case, the FPSC determined that CBCP is the most cost-effective
alternative.  The discussion of the conservation criterion
concluded that, since cogeneration is not necessarily a
conservation method, conservation and other demand-side
alternatives as envisioned by Florida Energy Efficiency and
Conservation Act are not germane to qualifying facility needs
determination.

It is recognized that the FPSC order satisfies their own
responsibilities in evaluating the need for the CBCP.  However,
this does not preclude the EIS process, which requires a clear
definition of need for a project in order to evaluate a
No-Action alternative and the alternative means of satisfying
the need.  After evaluating relevant documents prepared by the
FPSC and the Florida Electric Power Coordinating Group (FCG), it
has been determined that for this SAR/EIS the need for the
project will be based on the following: 1) need for additional
base load capacity of 225 MW for increased reliability in
service, 2) need for displacement of the future consumption of
2.2 million barrels of oil per year or equivalent volume of
natural gas, and 3) need for 640,000 pounds per hour
(pounds/hour) of process steam for use by the SK paper mill.

It is proposed that the CBCP be constructed on the site of the
existing SK paper mill in northern Duval County.  The site is
owned by SK.  The total existing paper mill site consists of 425
acres.  The new cogeneration facilities will occupy
approximately 35 acres at the site and is to be located west of
the existing mill and east of the Broward River and the mill
lime settling ponds.  The area to be occupied by the
cogeneration plant is currently used for storage of lime mud
from the mill and construction debris.  A rail yard is located
to the north and west of the proposed plant site.  Due to
previous disturbances, there is little vegetation on site.  The
existing vegetation is mostly grasses, weeds, and shrubs.

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The proposed plant will consist of three 75 MW CFB boilers, a
single steam turbine driven electrical generator, steam
pipelines to supply the SK paper mill, mechanical draft cooling
tower, coal handling facilities, coal and limestone storage
facilities, stormwater runoff control ponds and a 138 kilovolt
(KV) transmission line to transfer the power from the plant to
the JEA and FPL power network systems.  An interconnection from
the CBCP to the JEA electric power grid will be made by
constructing the transmission line from the cogeneration plant
to the JEA's Eastport substation, which is located directly
southeast and adjacent to the paper mill.

Initial site preparation will require the relocation of an
estimated 230,000 cubic yards of the lime mud which has been
stored on the plant site.  The lime mud will be placed in a lime
mud storage area in the northwestern portion of the SK
property.  Construction of the storage area will include a
geomembrane cap and seeded earth cover.

Construction of the proposed plant and its associated disposal
areas will disturb or eliminate approximately 30 acres of poor
quality, previously disturbed wildlife habitat.  Since paper
mill operations have cleared most of the area already, and
thereby reduced the value of this community as a habitat for
wildlife, additional destruction of these areas will certainly
hasten the demise of the biota associated with these areas.

The units are planned for coal-fired operation; however,
provisions are being made in the design to allow for burning of
wood waste as well.  Based on a study of availability of coal
sources east of the Mississippi River, there are practical
sources of coal adequate to meet the plant's needs over the
anticipated life of the project (approximately 1,105,000 tons
per year).  Coal is to be delivered to the site by train using
the existing CSX railroad lines.  The rail spur runs northwest
to southeast on the site.

The air quality control system is designed on a "worst case"
basis assuming the maximum sulfur (3.3 percent) and ash (18
percent) content in the coal and a minimum heating value (10,500
BTU/pound) .  The emission of air pollutants from the CBCP site
are limited by Chapter 17-2, FAC, and by the New Source
Performance Standards as imposed by the USEPA.   In order to
comply with these regulations, AES-CB proposes to utilize washed
coal with a fluidized limestone bed to control emission of
sulfur oxides.  Particulate matter will be controlled by a
fabric filter.  It is estimated that approximately 354,000 tons
per year of fly ash and 88,000 tons per year of bed ash could be
generated.  This material is to be disposed of by the coal
supplier at an approved disposal location outside the State of
Florida or sold to the building materials industry.



                                111   0-3

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When all of the units are operating at 100% of rated capacity,
the plant will consume 145 tons per hour of coal and will emit
1,913 pounds per hour of nitrogen oxides.  The stack height of
425 feet will assist the control equipment in reducing ambient
air quality impacts by insuring dispersion and dilution of air
pollutants before the pollutants reach ground level at some
distance from the site.  Only during rare meteorological
conditions will stack emissions reach the ground close to the
plant.

The primary source of water for the plant will be groundwater
from the Floridan aquifer.  Fresh groundwater or reclaimed water
from Jacksonville sewage treatment plants will be used as makeup
to the recirculating cooling water system.  Cooling towers will
be located at the south end of the CBCP plant area.  The maximum
discharge temperature of cooling tower blowdown is expected to
be 95 degrees Fahrenheit.

Wastewater from the construction and operation of the CBCP will
originate from a number of sources such as cooling tower"
blowdown, boiler blowdown, metal cleaning wastes, sanitary
wastes, site runoff, construction dewatering, and low volume
wastes such as demineralizer blowdown, floor drains and
laboratory wastes.  All of the wastewater, except excess
stormwater runoff, will be disposed of, after necessary
treatment or pretreatment, via existing paper mill treatment and
discharge facilities.  An erosion and sediment control plan has
been developed to minimize construction related runoff impacts.


3. Malor Plant Systems Alternatives

Alternative Sites

AES-CB stated in their Site Certification Application (SCA) that
the proposed site for the CBCP was an ideal construction site
because of its proximity to the steam customer, the SK paper
mill, and because the industrial nature of the proposed site (an
IH, heavy industrial, zone) has been extensively disturbed by
previous industrial use over the last 35 years.  Even though the
CBCP is in "compliance with local zoning ordinances, it must also
be found to be consistent with the North District Plan (NDP),
prepared by the planning department of the City of
Jacksonville.  Assuming that the project conforms to the NDP and
acknowledging that an alternative site would lengthen the steam
delivery line, thereby increasing heat loss and reducing plant
fuel use efficiency, further evaluation of alternative sites was
determined not to be necessary.

Air Pollution Control Systems

Air emissions control system alternatives ^ere evaluated
considering the state of the art of emission control technology,
                                IV

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environmental impacts/and economics.  Major sulfur dioxide
(802) control alternatives included proper CFB boiler design
and operation in conjunction with low sulfur coal, a pulverized
coal (PC) boiler followed by a wet limestone scrubber system,
and a PC boiler followed by a lime spray dryer system.  Based on
economics, energy, and environmental considerations, a CFB
boiler system designed to meet a 90 percent removal requirement
appears to represent Best Available Control Technology •(BACT).
Particulate control alternatives included fabric filters and
electrostatic precipitators.  The fabric filters were chosen
because of the high particulate control rate.  Alternatives to
controlling nitrogen oxides (NO.,) emissions include proper
boiler design and operation, selective catalytic reduction
(SCR), and selective noncatalytic reduction (SNRC, or Thermal
DeNOx) control technologies.  SNRC is the preferable
alternative for NOX control unless it can be shown clearly
that it does not represent BACT.

Cooling Systems

Cooling systems alternatives included the heat dissipation
system, the water source, and the discharge receiving body.  The
primary use of water at the CBCP will be for evaporation in the
heat dissipation system.  Alternatives examined for the heat
dissipation system include once-through cooling, dry and wet-dry
cooling towers, wet natural draft cooling towers, and mechanical
draft cooling towers.  Based on energy and economic
considerations, rectangular mechanical draft cooling towers were
chosen.  Use of surface water, groundwater, recycled wastewater,
and reclaimed water (municipal wastewater treatment plant
effluent) were the alternatives examined for the cooling water
source.  The CBCP will use groundwater from the Floridan aquifer
as its primary water source and draw from existing SK wells.  At
the time the City of Jacksonville can provide treated wastewater
of sufficient quality, the CBCP will use reclaimed water in the
cooling towers, with groundwater used only as a backup.  AES-CB
has agreed to the St. Johns River Water Management District's
(SJRWMD) condition that calls for the use of reclaimed water.
Cooling water discharge alternatives include discharge to the
Broward River, recycling of treated cooling water, or discharge
via SK's existing outfall into the St. Johns River.  Discharge
through the existing outfall is the chosen alternative.

Water/Wastewater Systems

Because of the high quality and low volume of water needed for
potable water uses, no alternative to groundwater use is
proposed for secondary water uses.  The primary use of water
will be for make-up to the cooling system, as described above.
Cooling tower blowdown will be routed directly to the existing
SK St. Johns River outfall.  Surface runoff and yard drains
during both construction and operation will be directed to
retention ponds after which it will be routed to the existing SK
treatment system or directly to the St. Johns River outfall.


                                v   C-S

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One recommended alternative is addition of sand/gravel filters
in the retention ponds for improved removal of silt.  All other
wastewater will be routed to the existing SK wastewater
treatment facilities.  Wastewater from construction dewatering
will be treated by AES before discharge to the existing SK
once-through cooling system.  Excess runoff from storms
exceeding the 10-year, 24-hour rainfall event may be discharged
to the Broward River.

Solid. Waste Systems

Alternatives were considered for disposal of high volume solid
wastes, which for the CBCP include bed ash and fly ash.
Alternatives to disposal of bed ash include wet sluicing to a
lined ash pond, wet sluicing to dewatering bins with landfill
disposal, mechanical ash removal with landfill disposal, and
pelletizing with disposal by the coal supplier outside of
Florida (or sold within the building industry).  Alternatives to
disposal of fly ash include wet sluicing to an ash pond for
disposal, vacuum conveyance with landfill disposal, and
pelletizing with disposal by the coal supplier.  Disposal
outside the State of Florida by the* coal supplier (or sold
within the building industry) is the chosen alternative for both
types of ash.


4.  Alternative Means of Satisfying the Need for the Project

Part 1502.14, Title 40 of the Code of Federal Regulations (40
CFR 1502.14) of the implementation regulations for NEPA require
that all reasonable alternatives to the proposed action be
considered in the EIS process.  The determination of need for
the CBCP is based on the need for additional electricity
generating capacity and for the displacement of future oil
consumption.  Analyses of alternative means of satisfying the
need for the project are to determine if the proposed project
represents the lowest cost and most environmentally sound ,
alternative available to provide electric power to FPL, to
displace future oil and/or natural gas consumption, and to
provide process steam for use by the SK paper mill.  The FPSC
did not consider any alternatives to fulfill these requirements
during their evaluation of need for this project.  Subsequently,
the FCG's 1989 Generation Expansion Planning Studies document
was used as the basis for alternative development for this
SAR/EIS.  The alternatives were selected based on their ability
to meet the following objectives:

    * the alternative must supply at least 225 MW of electric
    power;

    * the alternative must displace at least 2.2 million barrels
    of oil consumption or natural gas equivalent; and

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    * need for 640/000 pounds/hour of process steam for use by
    the SK paper mill.

Based on these criteria,.the following five alternative power
systems plus the No Action Alternative were developed for
evaluation in the SAR/EIS.

Alternative 1 - Purchase of Power

The purchase of power is dependent on the availability of power
from an outside utility and the availability of power
transmission.  As documented in the FCG's 1989 Generation
Planning Studies, in September 1985, a detailed study of the
economic viability of additional transmission capacity into the
state of Florida was completed.  This study evaluated the
cost-effectiveness of constructing additional transmission
facilities in order to raise the transfer capability above the
current 3,200 MW level.  The study reaches the conclusion that
it is unlikely that additional transfers from either the
Southern.Company or the Tennessee Valley Authority (TVA) above
the existing 3,200 MW transfer cap'ability would be economical
given the current fuel price outlook.  Also, a sensitivity
analysis showed minimal reliability benefit from an increase in
transfer capability.

Alternative 2 - Residential Solar Hot Water Heaters

Under this alternative, it is assumed that FPL would sponsor a
retrofitting of solar water heaters for 50% of all new and 10%
of all existing customers in its service areas.   Each solar
water heater unit is expected to replace the use of
approximately 2,100 kilowatt-hour (KWH)  of electricity per year
at the end of the installation period.  This replacement would
save FPL approximately 2.4 million barrels of oil per year.  The
solar water heaters would displace oil-fired generating
capacity,  and would generate no air pollutants,  wastewater
discharges, or solid wastes.  In addition, they would require no
increase in groundwater consumption.  The implementation of the
solar water heater program would also be expected to boost
employment by about 1,650 new jobs for each year of the program
in the area of manufacturing and installation of these units.
The use of these units, however, would require provision for
backup power sufficient to meet peak demand in case weather
conditions render them ineffective for an extended period of
time.   Other disadvantages of this alternative include the
complexity of coordination and implementation efforts, the
questionable reliability of the heaters,  and the large amount of
maintenance required.
                                  ..   c-i
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Alternative 3 - Construction of a Combustion Turbine Power Plant
                 with Coal Gasification

FPL or the applicant would build a combustion turbine power
facility with a capacity of 225 MW at the proposed project
site.  The facility would be comprised of three 75 MW gas
turbine generators with Heat Recovery Steam Generators (HRSG).
Fuel for the facility would be generated in a fully integrated
coal gasification system.  Gasification is the process by which
coal is converted into a combustible gaseous fuel for
consumption.  The coal gasification process generates a low BTU
gas to be burned in the gas turbines.  This is considered a
"clean coal technology" in that coal is gasified, the gas
generated is then scrubbed of particulates and ammonia and then
the sulfur is removed.  The coal gas can be a substitute fuel
for natural gas.  This type of power plant has the ability to
meet air emissions restrictions.  The installation of a
combustion turbine would not be economically feasible unless the
low pressure steam produced by the HRSG is utilized in some
process.  Disadvantages of this alternative include:  it
involves a highly complex refining process; the technology is
just starting to come out of the demonstration stage to
commercial viability; it may have problems with high CO2
emissions; and it requires a high level of maintenance.

Alternative 4 - Construction of a Combined Cycle Coal
                Gasification Power Plant

FPL or the applicant would build a combined cycle coal
gasification power facility with a capacity of 225 MW at the
proposed project site.  Gasification is the process by which
coal is converted into a combustible gaseous fuel for
consumption.  The facility would be comprised of a gasification
combined cycle plant with two 114 MW combined cycle units and a
gasification unit.  Each combined cycle unit would consist of
two gas turbines with associated HRSGs and one steam turbine.
The condenser cooling system would require a freshwater source
to cool through evaporation and heat transfer.  Primary plant
stack emissions would be S02 and NOj.  The combined cycle
technology has many advantages:  relatively low investment
requirements, phased construction/ high operating efficiency and
fuel flexibility (natural gas, fuel oil, or gas derived from
coal), and ability to meet air emissions restrictions.
Disadvantages of this alternative include:  it involves a highly
complex refining process; the technology is just starting to
come out of the demonstration stage to commercial viability; it
may have problems with high CO2 emissions; and it requires a
high level of maintenance.
                                      C-%

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Alternative 5 - Construction of a Conventional Coal-Fired Power
Plant

FPL or the applicant would build a conventional coal-fired power
plant with a capacity of 225 MW at the same site as the proposed
project.  The facility would comprise a single pulverized
coal/high pressure boiler with a steam turbine generator set.
Current design practices relative to NOX would need to be
incorporated in the boiler and burner designs.  These units are
highly efficient and are capable of burning low-cost widely
available coal.  However, operation of such a plant would
require expensive pollution control facilities to avoid major
environmental impacts on air quality.


5.  Summary of the Manor Environmental Impacts of the Proposed
     Project and the Alternatives

Proposed Project

The construction of the rail spur and new lime mud disposal area
will affect some of the resident gopher tortoise (Gopherus
polvphemus) population.  It should be noted that the den of a
gopher tortoise is extremely important as a retreat or
hibernaculum to no less than 30 vertebrate and invertebrate
species, and many of these organisms rely exclusively on the
tortoise burrow for shelter.   It may be necessary to relocate
gopher tortoise populations as well as some of the associated
species.

During plant construction, Class III water quality standards
will be met in the discharge of dewatering effluent during
construction of the CBCP, except for copper.  With respect to
copper, the effluent will be treated to achieve a quality at
least as good as existing ambient water quality in the Broward
River and  will be better than  the existing copper concentrations
in the  St. Johns River.  Accordingly, FDER has recommended that
a two year variance be  granted for copper.

Runoff  from unusable spoil material and lime mud which is to be
stockpiled on the north end of the SK site could potentially
affect  surface water quality and/or groundwater quality.
Details on how and where this  runoff will be directed has not as
yet been provided by AES-CB.

The major  operation impacts of the proposed project primarily
affect  air resources, the water quality of the St. Johns and
Broward Rivers, and groundwater resources in the area.  No
violation  of National Ambient  Air Quality Standards or
Prevention of  Significant Deterioration  (PSD) increments is
projected  for  the Jacksonville area or the Okeefenokee Swamp in

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response to operation of the CBCP.  In fact, the project as
proposed will result in overall reductions in ambient air
quality impacts.

Operation of CBCP will increase emissions of carbon dioxide.
Carbon dioxide is one of several  "greenhouse" gases which
collectively function to retain heat energy, effectively warming
the earth's surface.

During operation of CBCP, pollutant concentrations in the
wastewater discharge to the St. Johns River are projected to
comply with Class III water quality criteria, except for iron.
With respect to iron, the cooling tower will concentrate iron
present in well water since iron concentrations occur naturally
in the Floridan aquifer.  The background level of iron in the
St. Johns River frequently is above the Class III standard of
0.3 milligrams per liter.  The iron proposed to be discharged is
essentially equivalent to concentrations which presently exist
in the St. Johns River.  Accordingly, a variance for iron has
been recommended by FDER.
                                  m
Some drawdown of the Floridan Aquifer and increased long-term
potential for chloride intrusion in the Aquifer would result
from groundwater withdrawals at CBCP.  Due to existing drought
conditions the water pressure in artesian wells has dropped
significantly.  Artesian and pumped wells close to the site
could experience slight reductions in flow or yield.  The SJRWMD
has reviewed the proposed groundwater withdrawals and concluded
that the withdrawals would not cause saline water intrusion or
aggravate any of the existing saline water intrusions.  SJRWMD
also stipulated that at the time the City of Jacksonville can
provide treated wastewater of sufficient quality, the CBCP will
use reclaimed water in the cooling towers, with groundwater used
only as a backup.  AES-CB has agreed to the SJRWMD's condition
that calls for the use of reclaimed water,.

Alternatives

The No Action Alternative, the Purchase Power Alternative, and
Alternative 2 (Residential Solar Water Heaters) appear to have
little to no environmental impacts during construction and
operation.  This is misleading for the Purchase Power
Alternative because the evaluation only addressed local impacts
and not impacts at the site of purchase power generation which
in turn could be as significant as those impacts created by the
proposed project.

Alternative 2 appears to have a positive impact during
construction because of the creation of jobs.  Construction and
installation would create localized noise and traffic problems
at the individual residences for this alternative but thse
impacts would be extremely minor in comparison to the power
plant alternatives.  Although not environmental considerations,

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the complexity of coordination and implementation efforts and
the questionable reliability of the heaters must be considered
in the evaluation of this alternative.

Impacts for the power plant alternatives (Alternatives 3, 4, and
5) during construction and operation are similar to those
expected for the CBCP.


6.  Mitigation Measures for the Proposed Project

Several measures which would be employed to mitigate the
potential impacts of the proposed project on the surrounding
environment were identified during the environmental review
process.  The  relocation of affected animals (gopher tortoises)
will be done in consultation and conformance with the Game and
Freshwater Fish Commission requirements.  Construction- related
impacts on air resources will be mitigated by employing suitable
fugitive dust and burning emission controls.  Impacts of
construction on water resources can be mitigated by
implementation of a comprehensive erosion and sediment control
plan and effective treatment of wa'stewater discharges.  Addition
of sand/gravel filter systems to the retention ponds for
improved removal of silt is recommended.  A sedimentation pond
will be provided for construction impacted runoff.  A
physical/chemical treatment system will be required for plant
dewatering wastes.  Treatment by this system is needed to reduce
copper/ iron, zinc, and other metals.

Operation-related impacts will be controlled to the best extent
practicable.  Recirculating cooling towers (with dechlorination)
will be used to treat waste heat; sedimentation for stormwater
runoff; reuse for boiler blowdown; neutralization and/or oil
removal as pretreatment followed by further treatment in the SK
industrial waste treatment system (IWTS) for low volume wastes;
offsite disposal and/or physical/chemical treatment for metal
cleaning wastes; and sedimentation followed by further treatment
in the SK IWTS for coal, limestone, and ash storage area
runoff.  CBCP will use high quality treated wastewater in the
cooling towers when it becomes available, in lieu of
groundwater.  Air emissions will be controlled with fabric
filters and boiler design.  Fugitive coal dust, limestone dust,
fly ash, and spent limestone will be controlled with water spray
dust suppression systems, enclosed conveyors, and fabric filters
(filters for coal dust only at conveyor transfer points).  Total
suspended particulates in the cooling tower drift will be
controlled by the use of drift eliminators and by limiting the
cycles of concentration in the cooling system.  AES has set
aside money as part of the CBCP to plant trees in order to
mitigate carbon dioxide "greenhouse" effects.
                                     C-ll

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7.  Unresolved Issues

Numerous changes to the project scope and the SK mill processes
have occurred during the preparation of this EIS.  The following
unresolved issues need to be addressed before completion of the
FEIS and issuance of the NPDES permit.

Air Quality

It is unclear at this time whether SNCR should represent BACT
for the AES boilers.  Therefore, it is important that all
available information concerning the proposed level of BACT and
the SNCR alternative be submitted by AES prior to the issuance
of the FEIS.  This information should include, among other
things, a comparative analysis between the AES boilers and other
CFB's which have been required to install SNCR.  This analysis
should document any differences in energy, environmental, or
economic concerns, between the facilities so that a final BACT
recommendation can be made.

Erosion and Sediment Control Plan  .

Revisions to the Erosion and Sediment Control Plan submitted by
AES-CB will be necessary before it is consistent with
requirements of Part III.D of the draft NPDES permit and can be
considered an acceptable Plan.  Specific concerns include:
absence of inspection, monitoring and reporting requirements;
potential runoff from the lime mud storage area; potential
runoff from unusable material which is to be stockpiled on the
north end of the SK site; and apparently inadequate size of the
Yard Area Runoff Pond.

SK Conversion to Recycled Paperboard

SK is planning to convert their facilities to accommodate
recycled paperboard, replacing wood as a raw material in their
operations.  SK conversion to recycled paperboard will
significantly reduce the SK waste flow and will change the
characteristics of the combined SK/CBCP effluent from that which
has presently been provided in the SCA.  Reevaluation of the
waste  flow  is needed in the FEIS.  In addition, it is unclear
whether or  not wood wastes will be burned at CBCP after
conversion  to recycled paperboard.  This could affect air
quality evaluations.  Clarification is needed before issuance of
the FEIS.

Toxicity  of CBCP Waste  Stream

Some  agreement will  have to be established between AES-CB and SK
as  to  how resolution of  future toxicity problems will be
effected, should  they occur, if  CBCP wastes discharged into the
SK system prove to  be more toxic  than presently  anticipated and

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result in the SK effluent being acutely toxic.  Present
evaluation indicates that additional treatment and/or dilution
in the SK treatment system may render the combined waste not
acutely toxic.  However, the SK manufacturing process is being
modified and dilution flow will decrease in the future.  SK is
(and will remain) subject to toxicity monitoring of the total
effluent exiting its treatment system.  In addition, facilities
at SK (some of which may have been in operation for 10'to 20
years or more) may be approaching useful life expectancy.  EPA
has no assurance that SK will be in operation over the useful
lifetime of the CBCP.  Assurances on these points prior to FEIS
issuance are desirable.

Waste Effluent Treatment Systems

Details on treatment systems proposed for dewatering wastes and
metal cleaning wastes (both chemical and nonchemical) have not
been provided by AES-CB and therefore cannot be evaluated to
determine if adequate treatment can be provided to meet NPDES
requirements.  A thorough description of these treatment systems
is needed prior to FEIS issuance.

Groundwater

The SJRWMD required AES-CB to use the USGS groundwater flow and
transport models to perform a hydrologic investigation to
determine the impacts of the proposed withdrawals on existing
legal users and the impacts to the groundwater resources
itself.  Concerns relating to the limitations of this modeling
effort include the following:  1) large grid size used may have
masked significant localized effects; 2) normal faults neglected
in the model could possibly, on a smaller scale, allow chloride
contamination to increase in the upper water bearing zone; 3)
apparently existing pumpage rates were used rather than the full
permitted pumpage rates for the existing permitted uses; and 4)
assumption of constant head boundary conditions could bias the
piezometric head in the upper water bearing zone.  It is
recommended that sensitivity analyses be conducted to evaluate
the effects of these concerns.  Results of these analyses need
to be included in the FEIS.  In addition, if estimates of
anticipated future applications for groundwater withdrawals are
available, it is recommended that this information be included
in the analysis described above.
                                xm
                                       c

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8.  USEPA's Preferred Alternative and Recommended Action

It is anticipated that AES-CB and SK will resolve the
outstanding environmental issues associated with the CBCP.
Based on preliminary findings, USEPA tentatively proposes to
issue the NPDES Permit with conditions (See Appendix B, Draft
NPDES Permit).  CBCP appears to be an economically advantageous
project for Jacksonville, its citizens, and FPL and it.
customers.  Not only does it displace oil and/or natural gas,
but by providing steam to the SK paper mill, it allows for
removal of old boilers, thereby producing a net decrease in
emissions of air pollutants.  In addition, it provides
additional generating capacity for the utilities which would
have to be constructed at a later time as system demand rises
and older units are phased out of use.  Given the advantages
offered by CBCP and pending resolution of the outstanding
issues, USEPA finds the proposed project, CBCP, to be the
preferred alternative.  The environmentally preferable
components of CBCP are:

    * Ambient air guality will be improved in the Jacksonville
    area and in the Okeefenokee Swamp area.

    * Thermal water discharges as a result of the existing SK
    once-through cooling system will be significantly reduced.
    Elimination of this system will also eliminate entrainment
    and impingement of aquatic species into the SK cooling
    system.

    * Existing contamination near the site will be cleaned up,
    or monitored for potential remedial actions, as appropriate.

    *  Utilizing a previously impacted industrial site makes
    impacts on wildlife and wildlife habitat from the project
    minimal.

It must be noted that based on the initial findings of this
SAR/EIS, various system alternatives to the proposed project are
available which appear to be environmentally sound as well as
economically  feasible.  These are:

    * SNRC is the preferable alternative  for NOX control
    unless it can be shown clearly that it does not represent
    BACT.

    * At  the  time the City of Jacksonville can provide treated
    wastewater of sufficient guality, the CBCP will use
    reclaimed water in the cooling towers, with groundwater used
    only  as  a backup.  AES-CB has agreed  to the SJRWMD's
    condition that calls  for the use of reclaimed water.

     * The addition of  sand/gravel filters in the retention ponds
     for improved removal  of silt is a viable alternative.
                                 xiv
                                       C-\\

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9.  FDER's Recommendations

FDER has recommended certification of the Cedar Bay Project.
This recommendation is based on the following rationale:

    1.  Replacement of old pulp mill facilities by the- CBCP will
    reduce existing ambient air quality impacts.

    2.  Relocation of old lime mud piles to a proper area could
    alleviate an existing situation causing a violation of
    groundwater quality standards and reduce an additional
    loading of heavy metals to the St. Johns Estuary.

    3.  Discharges from the SK wastewater treatment system can
    contribute contaminants to the St. Johns River which already
    contains excessive amounts of those contaminants.  Proper
    operation of the wastewater treatment facility, use of
    mixing zones and approval of variances for some metals would
    allow certification to be granted.
                                  *
If the Cedar Bay Cogeneration Project should receive State of
Florida Certification, FDER recommends that the Conditions of
Certification (Appendix D) be imposed to ensure that the
construction and operation of the CBCP is in conformance with
the applicable standards, regulations and laws of this State and
that the facility have minimal adverse impact on the
environment.
                                           015
                                 XV

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       APPENDIX D

PERMIT NO. PSD-FL-137 AND
  FINAL DETERMINATION

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28*- '" 8 1  18:1Z   FROM OiH.FtftND C LfltJ FIRM
  '*
                                                       PftGE.802
                                              .V   - _

                                              ^-1
                                                                -
       Florida Department of Environmental Regulation

       Twin Towers Office Bldg. • 2600 Blair Stone Road • Tallahassee, Florida 32399-2400

                              *                      Ctf°1 **• Brownct
       Uwton Chile*. Governor .
                           March 28, 1991
  CERTIFIED HAIL - RETURN RECEIPT REQUESTED

 .Mr*  Jeff Swain .                                   •
  AES/Cedar Bay Inc.
  loot North  19th Street
  Arlington,  Virginia  22209

  Dear Kr. swain:   .                .  .

  Ret   AES/Cedar Bay Inc.
       Cogeneration Project,  PSD-FL-137

  Please find enclosed the  above referenced permit.  You have the right
  to petition for an administrative bearing pursuant to Section 120.57,
  Florida Statutes,  within  14 days of receipt of this permit or file a
  Notice of Appeal  pursuant to Rule .9.110, Florida Rules of Appellate
  Procedure,  within 30 days from the date this permit is filed with the
  ClerX of the Department.  Further, you may request a public hearing.
  Such request must be submitted within 30 days of receipt of this
  permit.

  If you have.any questions,  please call Barry Andrews at  (904)488-1344
  or write to me at the  above address.

                                   Sincerely,

                                             J>.s&

                                          ancy, P.E.
                                  c.  H.
                                  Chief
                                  Bureau of  Air Regulation..
CHF/kt

enclosure

cc:  J. Harper, EPA
     A. Kutyna, KE District
     K. Kurts, BESD
     T. Cole, Oertel & Hoffman
                                D-\

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(Wont)
  D-2-

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MAR
28:'S1 18:17    FROM O.H.FtftND C LAW FIRM
                                                              PAGE.083
             Florida Department of Environmental Regulation

             TWin Tbwcr, Office Bldg. • 2600 Blair Stone Ho*. • Tallahassee, Florida 32399-24OO
                                                            Carol M. Browne. Secretary
             Uwton CMte, Governor
                                             vuab«rt
    j&6/C*6ar Bay, Xac,
    looi sort* i»th street
    •Arlington, Y*  2220»
                                   Project!  Cogeneration Project








 follows:  .                            .






 and operated by AE$. Cedar Bay, Inc.





 lo^lortdi Power" i Light aswell as  low pressure process steam for
 the Seminole Kraft Corporation.
     Kitarooen   ox ides  will  be   controlled  by  the   9°od  ---
     SSalteristici  which are an inherent  part of the CFB  technology,




     filters. ' - .                 •

     Construction  'shall be in accordance with the permit application and
     aSottional  information submitted except  as otherwise noted  in the
     Specific Conditions.

     Attachments:
                                                          88-24  and  its
      1.   Power    plant  site  certification
          associated attachments,  dated January  19,  1990.
      2.   Letter from EPA dated March 27,  1991.
      3.   DER's  Final Determination dated  March  28,  1991.

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MAR 28?'.91  16:18   FROM O.H.F.ftND C LAW FIRM                    PAGE.
            COHDZTZOK8S
       •
    •1.    The   terms,   conditions,   requirements,    limitation*,   and
    restrictions  set forth in this  permit are "Permit Conditions"   and
    are  binding'and enforceable pursuant to  Sections 403.161,  403.727,
    or  403..859  through  403.861, Florida  Statutes.   The  permittee is
    placed  on • notice  that  the  Department  will review this  permit
    periodically  and may initiate enforcement action   for any violation
    of these conditions.

    2.   This  permit  is  valid  only  for  the specific  processes and
    operations  applied for ' and  indicated, in the  approved drawings or
    exhibits.   Any unauthorized deviation  from the approved drawings,
    exhibits, .  specifications,  or  conditions   of  this  permit   may
    constitute  grounds  for  revocation and  enforcement action  by the
    Department.

    3.   As provided in  Subsections 403.087(6) and  403.722(5), Florida
    Statutes, *• the issuance of  this permit does  not convey any  vested
    rights  or any exclusive privileges,  neither  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.   This permit  .is  .not a waiver  of or approval  of any
    other "~Department permit that may  be required for other  aspects of
    the total project which are- not addressed in the permit.

    4.   This  permit  conveys  no  title  to  land or  water, does  not
    constitute  State recognition or acknowledgement of  title,  and does
    not  constitute  authority  for the  use of  submerged lands  unless
    herein  provided and the necessary title or leasehold interests have
    been  obtained from the  State.  Only the  Trustees of the  Internal
    Improvement Trust Fund may  express State opinion as to title.

    5.   This permit does not   relieve the-permittee from  liability for
    harm or injury to human health  or welfare,..animal, or plant life, or
    property  caused by the construction or  operation of this permitted
    .source, or from penalties therefore; nor does it allow the permittee
    to  cause  pollution  in   contravention   of  Florida  Statutes  and
    Department  rules, unless specifically  authorized by an  order from
    the Department.

    6.   The permittee shall properly operate  and maintain the facility
    and  systems of  treatment  and control  (and  related appurtenances)
    that  are installed  or used  by the permittee to   achieve compliance
    with the  conditions  of this permit, as required by Department rules.
    This  provision  includes   the   operation  of  backup   or   auxiliary
    facilities  or similar systems  when necessary  to achieve compliance
    with  the conditions of the  permit and when required   by Department
    rules.

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MAR 2B:f91 IB: 18   F.ROM O.H.F.AND C LAW FIRM                   PAGE.BBS
    PZRXXTTEBs                       Permit HO.  AC J>BI>-rL-137
    AB8/cedax Bay Inc.               County i  i>uval

    OZHZR&L COHDXTI0H8I

    7.   The permittee, by accepting this permit, specifically agrees to
    allow   authorised  Department   personnel,    upon  presentation  of
    credentials  or ether documents as may  be required by law and  at a
    reasonable  time, -access  to  the  premises,  where  the  permitted
    activity is located or conducted tot

         a. Have  access to and copy any. records that must be kept under
            the conditions of the permit;

         b. Inspect  'the facility,  equipment,  practices, or operations
            regulated, or required under this permit; and

         c. Sample   or  monitor  any . substances  or 'parameters  at any.
          •  location reasonably necessary to assure compliance with this
            permit or Department rules.           .
           * *            *• *               *
    Reasonable  time may  depend   on  the  nature  of the concern being
    Investigated.

    8.   If,  for  any reason, the permittee  does not comply  with  or will
    be   unable to comply with  any  condition or limitation  specified  in
    this permit, the permittee shall  immediately provide the Department
    'with the  following  information:

         a i a description  of and  cause of  non-compliance; and

         b. the  period of noncompliance,  including 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-compliance.

    The permittee shall be responsible for any and all damages  which may
    result  and nay be subject  to enforcement action by  the Department
    for penalties or for revocation of this permit.

     9.    In accepting this permit,  the  permittee understands and agrees
    that  all  records,  notes,   monitoring  data and  other information
    relating  to the construction or operation  of this permitted source
    which  are submitted to the Department' may be used by the Department
     as evidence in any enforcement case involving the
    permitted  source arising under  the Florida statutes  or Department
     rules,   except where such use  is proscribed by Sections  403.73 and
     403.111,   Florida Statutes.   Such evidence shall only be used to the
     extent  it is consistent with  the Florida Rules of  Civil Procedure
     and appropriate evidentiary rules.

     10.  The permittee agrees to comply with changes in  Department rules
     and Florida Statutes after a reasonable time for compliance,
                               Page   3  of  13

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MftR 2B.'*91  18:19   FROM O.HtF.ftND C LflU FIRM                    PAGE.886
                                     Permit Ho.  AC PSD-FL-137
    AXfi/Cedar Bay Inc.               county:  Duval

         XL COHDXTXOXfll
    provided,  however, the  permittee  does not valve  any other rights
    granted by Florida Statutes or Department rules.

    11.   This permit is transferable  only upon Department approval  in
    accordance  with  Florida  Administrative  Code  Rules 17-4.120  and
    17-30.300, F.A.C., as applicable.  The permittee shall be liable for
    any  non-compliance of the permitted' activity,  until the transfer is
    approved by the Department.

    1*2.  This.permit or a copy thereof shall be kept at the work site of
    the  permitted activity.

    13.  This permit .also constitutes: '     .  •

          (x)  Determination  of Best Available Control Technology  (BACT)
          (x)  Determination  of Prevention of Significant Deterioration
               (PSD)
          (x)  Compliance with New Source Performance Standards

    14.  The permittee shall comply with the following:

         a. Upon request, 'the permittee  shall  furnish all  records and
            plans   required  under Department rules.   During enforcement
            actions,   the  retention   period  for   all  records   will be
            extended  automatically unless  otherwise  stipulated by the
            Department.

         b. The permittee shall hold at the  facility or other  location
            designated  by  this permit   records   of   all  monitoring
             information  (including all calibration and maintenance
            records   and  all  original  strip   chart   recordings  for
             continuous  monitoring   instrumentation)  required   by  the
            permit,  copies  of all reports required  by  this permit,  and
             records  of  all  data used to complete  the application for
             this  permit.  These  materials  shall be retained  at least
             three  years  from  the  date  of  the  sample, measurement,
             report,   or  application  unless  otherwise   specified  by
             Department rule.

         ,c.  Records of monitoring information shall include:

             -  the   date,  exact  place,    and  time  of   sampling  or
                measurements;
             -  the  person responsible  for performing  the sampling  or
                measurements;
             -  the dates analyses were performed;
             -  the person responsible for performing the analyses;
             -  the analytical techniques or methods used; and
             -  the results  of such analyses.

                                     P-fc

                               Page   4 of 13

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MftR 28.-'91  18:19   FROM OtHiF.ftND C LflU FIRM                    PAGE.BB7
    PEEJCITOIJ       .                Permit KO.  AC PSD-PL-1J7 .
    Asa/cedar »ay Inc.               couatyt  mival

    General Conditions:

    15.   Khen requested by the Department, the permittee •hall vithin a
    reasonable  time furnish  any  information required by  lav which is
    needed  to determine compliance with  the permit.  If the  permittee
    becomes aware that relevant facts were not submitted or were
    incorrect  in  the  permit  application  or  in  any  report  to the
    Department, such facts or information shall be corrected promptly.
       *                        .
     •                        •

    SFlCXrXO CONDITIONS I

    1.   The construction and operation of AESCB  shall be' in accordance
    with all  applicable  provisions  of  Chapters  17-2,  *«*;c;;   .ln
    addition  to the   foregoing,  AESCB shall comply with. the  following
    conditions of certification as
         A.  .  Emission Limitations 'for AZS Boilers

         1.   Fluidized Bed Coal Fired Boilers (CFB)

         a.   The maximum coal charging rate of each CFB shall neither
         exceed 104,000 Ibs/hr, 39,000 tons per month (30 consecutive
         days), nor 390,000 tons per year (TPY) . This reflects a
         combined total of 312,000 Ibs/hr, 117,000  tons per month,  and
         1,170,000 TPY for ail three. CFBs.

         b.   The maxisum wood waste (primarily bark) charging rate to the
         No. 1 and No. 2 CFBs each shall neither exceed 15,653 Ibs/hr,
         nor 63,760 TPY.  This reflects a combined total of 31,306
         Ibs/hr, and 127,521 TPY for the No. 1 and No. 2 CFBs.  The No. 3
         CFB will not utilire woodwaste, nor will it be equipped with
         vood waste handling and firing equipment.

         c.   The maximum heat input to each CFB shall not exceed 1063
         XMBtu/hr.  This reflects a combined total- of 3189 «KBtu/hr for
         . all three units . .

         d.   The sulfur content of the coal shall not exceed  1.7% by
         weight on an annual basis.  The  sulfur content shall not exceed
         3.3% by weight on a shipment (train load) basis.

        • e.   Auxiliary fuel burners  shall be fueled  only with natural  gas
         or No. 2 fuel oil with a maximum sulfur content of  0.3% by
         weight.  The fuel oil or natural gas shall  be used  only for
         startups.  The maximum annual  oil usage shall not exceed  160,000
         gals/year, nor shall the maximum annual natural gas usage exceed
         22.4 KMCF per year.  The iriaximuro heat  input from  the fuel oil or
         gas shall not exceed  1120 KKBtu/hr for the CFBs.

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MflR 28 .-'91 18:20   FROM O.H.F.ftND C LAW FIRM
                         pflGE.eee
    juts/Cedar Bay Inc.
permit »o. xc
Countyi  Duval
         f.. The CFBs  shall be fueled only with the fuel* permitted in
         Condition* la,  Ib, and le above.  Other fuel* or waste* «hall
         not be burned without prior specific written approval of the
         Secretary of  DER pursuant to condition XXI, Modification of
         conditions.
                                          •       »•
         g.  The CFBs  may operate continuously, i.e, 8760 hrs/yr.

         2.  Coal Fired  Boiler Controls

         The emissions from each CFB shall be controlled using the
         folloving systems:.

         a.  Limestone injection, for control of sulfur dioxide.
         b.  Baghouse, for control  of particulate.

     3.  Flue  gas emissions from each CFB shall not exceed the following:.

                                    Emission Limitations
                                               •PPV    TPY  for  3 CTB5
CO
NOX
S02

VOC
PM .

HoSO4 mist
Fluorides
Lead .
Mercury
Beryllium
0.19
0.29
0.60 (3-hr avg.)
0.31 (12 KRA)
e/ois
O.020
0.020
0.024
0,086
"0.007
0.00026
0.00011
202
308.3
637.8
329.5
16.0
21.3
21.3
25.5
91.4
7.4
0.276
0.117
823
1256
•-
1338
££
87
86
103
374
30
1.13
0.5
2468
3767
—• •
4015
121
260
257
308
1122
91
3.
1-










4
5
     Uote:  TFY represents a 93% capacity factor.  MRA refers to a twelve
     month rolling average.

     4.  .Visible emissions  (VE) shall not exceed 20% opacity (6 min.
     average), except for one 6 minute period per hour when VZ shall not
     exceed 27% opacity.

     5.  Compliance with the emission limits shall be determined by EPA
     reference method tests included in the July 1, 1988 version of 40
     CFR Parts 60 and 61 and listed in Condition No. 7 of this permit or
     by  equivalent methods  after prior DER approval.
                                   P-S
                                Pace  6 of 13

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MAR 28 '91 18:20   FROM O.H.F.AND C LflU FIRM                   PAGE.809
    PERXITTZZJ                       Permit Ho. AC P8D-FL-1J7
    &BS/Cedar Bay Inc.               County:  Duvel

    6.  The CTBs are subject to 40 CFR Part 60, Subpart Da;  except that
    where requirement* within this certification  are more restrictive,
    the requirements of this certification shall  apply.

    7.  Compliance Tests for. each CFB

        a.  Initial compliance, tests for PK/PM10, S02, NOx,  CO,  VOC,
        lead, fluorides, mercury, beryllium and H2S04 mist.shall be
        conducted in accordance with 40 CFR 60.8  (a),  (b), (d),  (e),  and
        (*)•
                   *
     "  b.  Annual compliance tests shall be performed for PM,  S02 and
        NOx, commencing no later than 12 months from the initial test.

        c.  Initial and annual visible emissions compliance tests -shall
        be determined in accordance with 40 CFR 60.11(b)
        and  (•)«        '
     .                                   •
        d.  The compliance tests shall be conducted between 90-100% of
        the maximum liscensed capacity and  firing rate of each permitted
        fuel.            '

        e.  The following test methods and  procedures  of 40 CFR Parts 60
        and  61  or other DER approved methods with prior DER approval
        shall be used for compliance testing:


     (1)  Method 1 for selection  of sample  site and  sample traverses.
     (2) . Method 2 for determining  stack gas flow rate. •
     (3)  Method 3 or  3A for gas  analysis for  calculation of percent 02
         and CO2.
     (4)  Method 4 for determining  stack gas'moisture content to  convert
         the flow rate  from actual standard cubic feet to dry standard
         cubic  feet.
     (5)  Method 5 or  Method 17 for particulate matter.
     (6)  Method 6,  6C,  or 8 for  502.
     (7)  Method 7,  7A,  7B, 7C, 7D, or 7E  for  nitrogen oxides.
     (8)  Method 8 for sulfuric acid  mist.
     (9)  • Method 9 for visible emissions,  in accordance with 40  CFR
         60.11.
     (10) Method 10  for  CO.
     (11) Method 12  for  lead.
     (12) Method 13B for fluorides.
     (13) Method 25A for VOCs.
     (14) Method 101A  for mercury.
     (15) Method 104'for beryllium.
                                 "D-6!
                               Page  7 of 13

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MAR 28. '91  18:21    FROM O.H.FtflND C LftU FIRM                    PftGE.BIB
    PSMCXTTZII                       Permit »o.  xc pflD-n,-i37
   .AW/Cedar Bay mo.               county t  Duval

      • •       •
    •8.- -continuous Emission Monitoring for each CFB AESCB shall    _
    Continuous. Emission Monitors (CEMS) to determine coppUance.  CEKS
    for opacity, SO2, NOx, CO, and 02 or C02, shall be installea,    •
    calibrated, maintained and operated for each unit, in accordance
    vith 40 CFR 60.47a and 40 CFR 60
    Appendix F.

       a.  'Each continuous emission monitoring system (CEMS) shall meet
       performance specifications of 40 CFR 60, Appendix B.

     ' b.  CEMS data shall be recorded and reported in accordance with
       Chapter 17-2, F.A.C., and 40 CFR 60.  A record shall  be kept for
       periods of .startup, shutdown end malfunction.
        c.   A malfunction means  any sudden and
        pollution control equipment or process equipment to JP«^e *n *
        normal or usual manner.   Failures that are caused entirely or in
        part by poor maintenance, careless operation or any^ ^°^vaftlim
        preventable upset condition or preventable equipment breakdown
        shall not be considered  malfunctions.

        d.   The procedures  under 40 CFR 60.13 shall  be followed for
        installation, evaluation and  operation of all CEKS.
        «.  Opacity monitoring system data shall be reduced to
        Jveragts, based on 36 or more data points, and gaseous CEKS data
        shall be reduced to 1-hour averages, based on 4 or more data
        points, in accordance with 40 CFR 60.13(h).

     "   f .  For purposes of reports required under this certification,
        eicess emissions are defined as any calculated Average «i»««J
        concentration, as determined pursuant to Condition No. "herein,
        which exceeds the applicable emission limit in Condition No. 3.

     9.  operations Monitoring for each CFB

        a.  Devices shall be installed to continuously monitor and record
        steam production, and flue gas temperature at the exit of  the
        control  equipment.

        b.  The  furnace  heat load shall be  maintained between 70%  and
        100% of  the design  rated capacity during normal  operations.

        c.  The  coal,  bark, natural  gas and No. 2 fuel  oil  usage shall be
        recorded on a 24-hr (daily)  basis  for each CFB.
                                    P-10

                                pace  S of 13

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MflR 28 '31  18:22    FROM OtH.F.RND C LflU FIRM                    PftGE.Bll
    PZRXXTTZEl              •         Strait Ko. XC PSD-FL-137
    ftZ8/cedar Bay mo.               county:  Duval

    ip.  Reporting .for each CFB

       »  A miniaua of thirty (30) days prior notification of  compliance
       Jest shSlTSe givenlS DERI'S HIE. District office and to the BESD
       ' (Bio-Svironmental. Services Division) office,  in accordance with
       40 CFR 60.                                             •

       b.  The results of compliance test shall be submitted to the BESD
       office vithin 45 days after completion of the test.

       e  »rhe owner or operator shall submit excess emission reports to
     ' IES£ iHSorlanlfwith 40 CFR 60.  The report shall include the
       following:

      (1)  The magnitude of  excess emissions computed in accordance with
    40 CFR 60.13(h), any  conversion factors used, and the date and time
    of commencement and completion of each period .of excess emissions
     (2)   Specific identification of  each period of excess emissions that
     occurs during startups,  shutdowns, and malfunctions of the /Jjrnace
     boiler system.  The nature and cause of any malfunction  (if known)
     and the corrective action taken  or preventive measured adopted
     (60.7(C.)(2)).

     (3)   The date and time identifying each period during which the
     continuous monitoring system was inoperative except for  zero  and
     span checks, and the nature of the system repairs or adjustments
     (60.7 (e) (3)).

     (4)   Khen no excess emissions have occured or the continuous
     monitoring system has not been inoperative, repaired,  or adjusted,
     such information shall be stated in  the report  (60.7(c) (4)) .

     (5)   The owner or operator shall maintain a file of all
    .measurements, including continuous monitoring systems  performance
     evaluations; monitoring systems or monitoring device .calibration;
     checks; adjustments and maintenance  performed on these systems or
     devices; and all other information required by this permit recorded
     in a permanent form suitable for inspection (60.7(d)).
                                          *
         d.  Annual and quarterly reports shall be submitted to BESD as
         per F.A.C. Rule 17-2.700(7).

     11. Any change in the method of operation, fuels utilized,
     equipment, or operating hours or any other changes pursuant to
     F?A.C. Rule  17-2.100, defining modification,  shall be submitted for
     approval to  DER's Bureau  of Air Regulation.
                                  P-U
                                Page   9  of  13

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MAR 28 '91 16:22   FROM O.H.FtftND C LAU FIRM                   PAGE.BIS
    PZBXITTZIl                       Permit HO.  AC PfiD-FL-137
    JUBS/Cedar Bay X&e.               Couatyz  Duval

    • B«  AES - Katerial Handling and Treataent
                       *                           •
    1.  The material handling and treatment operations nay be
    continuous, i.e. 8760 hrs/yr.

    2.  The material handling/usage rates shall not exceed the
    following:

                                      Handling/Usage Rate
              flaggy jp 1                TPK             TPY

              Coal                  117,000      1,170,000
              Limestone              27/000        320,000
              Fly Ash                28,000 •       336,000
              Rfd Ash                 8.000         88,000

    Mote: TFK is tons per. month based on 30 consecutive days, TPY is
    tons per  year.

    3.  The VOC emissions from the maximum Mo.  2 fuel oil utilization
    rate of 240 gals/hr, 2,100,000 gals/year  for the limestone dryers;
    and 8000  gals/hr,  160,000  gals/year for the three boilers are not
    expected  to be significant.

    4.' The maximum  emissions  from the material handling  and treatment
    area, Where baghouses are  used as controls  for specific sources,
    shall not exceed those  listed below  (based  on AP-42 factors):


                                       .Particulate Emissions
Coal Rail Unloading
Coal Belt Feeder
Coal Crusher
Coal Belt Transfer
Coal Silo
Limestone Crusher
Limestone Hopper
Fly Ash Bin
Bed Afih Hopper
Ash Silo
Common Feed Hopper
Ash Unlcader 	
neg
neg
0.41
neg
neg
0.06
0.01
0.02
0.06
0.06
0.03
0.01
neg
neg
1.78
neg
neg
0.28
0.03
0.10
0.25
0.25
0.13
0.06
     The emissions from the above listed sources and the ,li»estone dryers
     are subject to the particulate emission limitation requirement of
     0.03 gr/dscf .  However, neither DER nor BESD will require
     particulate tests in accordance with EPA Method 5 unless the
                                Page   10  of  13

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MftR 28 '91  18:23   FROM O.H.F.ftND C LAUI FIRM
                                                             PRGE.B13
    particuiate •mission limit, are being violated.
     with r.A.c. Chapter 17-
     Tabll 1,  3-1,  industrial Distillate,

                                    Estimated Limitations
Pollutant
PK/PKio
CO ' • •'
NOx
VOC 	
ifag rwr
0.25
5.00
0.60
2.40
0.05
Ufa ^r.i
1.1
21.9
'2.6
10.5
0.2
L^^B^K^i^fl^
2.2
43.8
5.2
21.0
A A
	 SLvi
         in
                              1. 4-1.  In*»trUl 10/86.
     7.  ate •»!»» Ho. 2 «u.l oil tiring «*. «« «!*
                                      5fi°;rs«r5fi5S:
                                      »,. for «ch Intone dryer
      not exceed 16,800 CF .per hour, or 147 KMCF per year

      8.   initial and annual Visible Emission compliance tests for  all the
      emission points in the material handling and £jatojntar.a,^^
      including but not limited to the sources specified in this permit,
      SaUbe" Conducted in accordance with the July 1. 1988 version  of 40
      CFR 60,  using EPA Method 9.
      9.  Compliance test reports shall 'be       ^,^0^
      days of test completion .in accordance with Chapter

      the F.A.C.

        . '  Any .changes in the method of operation, raw
             • _      •    _ A.   ^*_  —._^.«.«.^ *s w^^w v»^*i^>»c r\^r n^v
submitted for approval  to
                                     Bureau of Air Regulation
                                   D-i3
                                Pace  11 of 13

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MRR 2B..'S1  18:23   FROM O.H.F.ftND C LftU FIRM                    PAGE.014
    PERMITTEE:                        Permit MO. AC PSD-rL-137
    JUtf/Cedar Bay Inc.               Countyt  Duval

    C. Requirements For the Permittees

    1.  Beginning one »onth after certification, AESCB  shall submit to BESD
    and DER's BAR, -a quarterly status report  briefly outlining progress
    nade.on engineering design and purchase of major equipment, including
    copies of technical data pertaining to the selected emission control
    devices. 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 reviev of
    these data, disapprove the use of any such device.   Such disapproval
    •hall be issued within 30 days of receipt of the technical data.

    2.  The permittees shall report any delays  in construction and
    completion of the project which would delay commercial operation  by
    more than 90 days to.the BESD office.

    3.  Reasonable precautions to prevent fugitive  particulate  emissions
    during construction, such as coating of roads  and construction sites
    used by contractors, regressing or watering areas of disturbed soils,
    will be taken by the permittees.

    4.  Fuel shall .not be. burned in any unit unless the control devices are
    operating properly/ pursuant to 40 CFR Part 60 Subpart Da.

    5.  The maximum sulfur content of the Ho. 2 fuel oil utilized in the
    CFBs and the two unit limestone dryers shall not exceed 0.3 percent by
    weight.  Samples shall be taken of each fuel oil shipment received and
    shall be analyzed for sulfur  content and heating value.  Records of the
    analyses shall be Kept a minimum  of two years to be available for DER
    and BESD inspection.       •

    6.  Coal fired in the CFBs shall  have a  sulfur content not to exceed
    3.3 percent by weight.  Coal  sulfur content shall  be determined and
    recorded in accordance with 40 CFR 60.47a.

    7.  AESCB  shall maintain  a daily log  of  the amounts and types of fuel
    used and copies of  fuel analyses containing information on sulfur
    content and heating values.

    8.  The permittees  shall  provide stack sampling facilities as required
    by Rule 17-2.700(4) FAC.

    9.  Prior  to  commercial operation of each source,  the permittees shall
    each submit to the  BAR a standardized plan or procedure that  will  allow
    that permittee to monitor emission control equipment efficiency  and
    enable the permittee  to return malfunctioning  equipment to proper
    operation  as  expeditiously as possible.
                               Page  12 of 13

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MflR 28 '91  18:13   FROM O.HiF.flND C LftU FIRM                   PAGE.084
    PZSXXTTE2*                       permit So.  &o PBD-TL-WT
    JLEfi/cedar Bay Inc.               County i  Duval

    D.   Contemporaneous Emission Reductions

    This certification and any individual air permits issued subsequent to
    the final order, of the Board certifying the power plant sit* under
    403.509, F.S., shall require, that the following Eeminole Kraft
    Corporation sources be permanently shut down and made incapable of
    operation, and shall turn in their operation permits to the Division of
    Air. Resources Management's Bureau of Air Regulation, upon completion of
    .the initial compliance tests on the AESCB boilers: the No. 1 PB (power
    boiler), the No. 2 FB, the No. 3 PB, the Ho. 1 BB (bark boiler), and the
    No. 2 BB.  BESD shall be specifically informed in writing within thirty
    days after each individual shut down of the above referenced equipment.
    This, requirement shall operate as a joint and individual requirement to
    assure common control for purpose of ensuring that all commitments
    relied on are in fact fulfilled.
                                           Issued this       day
                                           of /Hfti/-J? _ , 1991
                                           STATE OF FLORIDA DEPARTMENT
                                           OF ENVIRONMENTAL REGULATION
                                           Carol M. Browner, Secretary
                              Page   13  of  13

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HRR 28  "9.1  18:24    FROM O.Mil-tHNU c  ci-iw  rir\it
                                     Attachment 1
                                Ateilable Upon Request

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MflR 28 '91 18:24   FROM O.H.F.ftND C LftU FIRM                     PAGE.B16
                               .Attachment 2
                                           17

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MflR 28.. '£1  18:24   FROM OtH^jAND C LftU^FIRM. ^ ^  ^  ____         PftGE^l?




                UNITED 5'. ATES CNVmONMENTAL PROTECTION AGENCY


                                  HC& ION IV .
 4APT-AEB
                               COURTUANO STHECT. NJL.

                             ATLANTA.. CEOW&I*
     Clair H. Fancy, P.E., Chief
        of Air Regulation
  Fa'gulation  .          •
  vin Towers Office Building-
 2«00 Blair Stone  Road
 VAllahAs»e», Florida . 32399-2400

 jai '-Preilainary. Oeteraination for XES/Cedar Bay  (PBD-FL-137)


 DWLT Hr.  raneyt              *              •




 pftckaye as requested end luve the following cca«aent«.
  Tbe public notice submitted in the packaje ww              f
  Site Certification Process.  The^otice J
  with the Site Certification Hearing
public notice axe e-e *ello%cet

    1.  The notice states that DER has  b**n ^ranted ad ele
    EPA to carry out the PSD review process.  AS  you knov,
    a SIP approved state rather  than  a  delegated  state.



   '
    AES/Cedar Bey.  As  detailed  to you  in our letter of
    November 14, 1989,  and as  acknowledged on page 33 of your     _
    preliminary determinationf netting  of emissions^fcetw
    Kraft and ASSCB  is  not applicable.   Thus, the a.ncrew
    consumption reported in the  public  notice .
                                                              t
                                                    not correct.

-------
riri rt c.o
                                   -2-
            •
 The determination of BACT aede by PER included  conbuetion controls to
 limit MO. eaieeions and a 602 renov&l efficiency of 90% resulting
 in «aie«Ion llaite of 0.29 15 »0X/KHDTO end 0,31 Ib S02/KKBTU.
 Thes* littits fere higher than what is currently  being permitted even
 for pulverized coal boilera.  Me believe that NOX  e,dd-on controls
 are technically feasible for this project and that S02 •niseion*
 could be reduced through the use of lover eulfur coal and thruugh
• increasing the removal efficiency.  However, due to the circumstances
 involved in thia project, we vill defer to the  decision of DER for
 this
                       *                  .                .
 If you have any questions on these coasnents,  please contact
   . . Gregg Vorley of »y staff at (<04)  347»2S04.
 Sincerely yours,
         \  -•
  inston A. .Smith/ .Director
 Air, >esticides , and. Toxics
  Management

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18:13   FROM  O.H.F.flND C LflU FIRM                   PftGE.003
                  Final Determination
                    AES/Cedar Bay Inc.
                   Cogeneration Project
                  Duval County, Florida
                  Permit No:  PSD-FL-137
      Florida Department of Environaental Regulation
           Division of Air Resources Managenent
                 Bureau of Air Regulation
                       March 28,.1991

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MPR 28;'SI  18:16    FROM O.HtFiftND C LftU FIRM                    PAGE.0BS
                              Final Determination
     AES/Cedar Bay, Xnc.'s PSD permit application (part of the Power Plant
     Siting application) , has been reviewed by the Division of Air
     Resources Management.  Comment* received from EPA Region IV dated
     March 27, 1991 (see attachment 2) are addressed below.
            notice
     The EPA questioned vhy the notice was published on the sane date that
     fche Site Certification Hearing was scheduled to begin, thereby not
     providing a 30 day notice and comment period.

     Notice vas published originally on December 8, 1989, for a January 8,
     1990 hearing.  A copy of the proposed Kotice was sent to Region IV on
     December 1, 1989 for review.  No comments were received regarding the
     increment consumptions reflected in the Kotice sent to EPA.  The
     hearing was then postponed fron January 8, 1990 to February 5, 1990.
     The hearing then had to be continued on February 20, 1990 for which
     the Notice was published on February 12, 1990.  In addition, public
     access hearings were held on February 7, 1990 and February 21, 1990
     for nonparty members of the public.  The public always has the right
     to speak.  Only if they intervene as a formal party do they need an
     attorney as required by Florida law.

          Analsis
      The  Department agrees vith EPA that add-on NOx controls are
      technically feasible for the AES/Cedar Bay project.   The decision to
     •establish the NOx limitation at  0.29  Ib/MKBtu was  based on the overall
      benefits that would be  obtained  from  the construction of the
      Regeneration facility (the additional cost of SNCR would cause the
      project to become financially unfeasible).  The  circulating fluidized
      bed  (CFB)  boilers will  replace older  boilers which have higher
      emissions per heat input.  In addition, the 0.29 Ib/MMBtu limitation
      was  judged to be the most stringent limitation placed on a coal fired
      boiler which does not have add-on NOx controls.

      For  sulfur dioxide, the pepartment evaluated the cost of switching to
      a lower sulfur coal and determined, that such a cost  was prohibitive.
      It should be noted that the decision  .to limit the average annual
      sulfur content to 1.7 percent is well below the  initial proposal of
      3.3  percent by the applicant.  With regard to the control efficiency,
      the  Department believes that 90  percent efficiency is reasonable for
      the  CFB design.
                                    D-2.

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 \  §
N

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           APPENDIX E

FLORIDA PUBLIC SERVICE COMMISSION
  ORDER GRANTING DETERMINATION
          OF NEED AND
ORDER APPROVING SECOND AMENDED
    COGENERATION AGREEMENT

-------

-------
          BEFORE THE FLORIDA PUBLIC SERVICE COMMISSIpy P f^ p  ,
                                                       *" ^ s      V r  Q

In re:  Petition of AES Cedar Bay, Inc. )   DOCKET NO.  88^47.2-EQ
and Seminole Kraft Corporation for      )                   *-   0 1989
determination of need for the Cedar     )   ORDER NO.  21491          u^
Bay Cogeneration Project.               )               rx,-.^
  1   *                            	)   ISSUED:    6-fi>£B9 ,
	—	                  ^ <-"%,„

     The    following    Commissioners   participated   in    the
disposition of this matter:

                  MICHAEL McK.  WILSON,  Chairman
                         THOMAS M.  BEARD
                          BETTY EASLEY
                        GERALD L. GUNTER
                         JOHN T.  HERNDON


              ORDER GRANTING DETERMINATION OF NEEQ7 f

BY THE COMMISSION:

     On  November  10,  1988,  AES Cedar   Bay,  Inc.   (AES)  and
Seminole  Kraft   Corporation  (Seminole  Kraft)  filed  a   need
determination  application with the  Department  of Environmental
Regulation  (DER)  and a  petition  for determination of  need  with
this  Commission  pursuant  to  the  provisions  of   the  Florida
Electrical  Power   Plant  Siting  Act  (Siting  Act),  Sections
403.501-.517, Florida Statutes.

      In  its petition,  AES has  requested  that  it  be allowed to
build  a  225  MW   circulating  fluidized  bed  coal   qualifying
facility  (QF)  located  at  an existing  industrial  site adjacent
to  and  on  the  property of  the  Seminole Kraft  paper  mill in
Jacksonville, Florida.   All  of the electricity produced by  this
QF  will  be  sold to Florida  Power and Light Company (FPL)  under
the  terms  of  a negotiated  agreement.  ''On  December  13,   1988,
this  agreement was submitted  to  the Commission for approval in
Docket No.  881570-EQ.

      On  January 4, J.989,,,the .Statf .filed a jnotion to impleed
FPL  as an  indispensable  party in this docket.  This  motion was
denied by the prehearing officer  on January  30,  1989, in  Order
No.  20671.   The direct  testimony of Gerald J. Gorman, Kerry. G.
Varkonda, Lawrence  A. Stanley,  and Dennis  W.  Bakke was filed on
March 13,  1989.  The  direct  testimony  of Jeffrey V. Swain and
Myron R. Rollins  was  filed on  March 14,  1989   and  March  15,
1989,  respectively.  The direct  testimony  of  Juan E. Enjamio
and Joseph  C.  Collier was filed on March  17,  1989 anu March 20,
1989,  respectively.  All of these witnesses  submitted testimony
on  behalf of AES  and  Seminole  Kraft.

      This  docket  was  heard  in  conjunction  with  Docket  No.
881570-EQ,  Florida Power and Light's  petition for approval  of
its  cogeneration  agreement  with  AES,  on  April 24 and 25,  1989
before the  full Commission  and was  subsequently voted on  at the
agenda conference  of  June 6, 1989.

      In  evaluating  a  petition for determination of  need, we are
bound by the  statutory  requirements of  Sections 403.507(1)(b)
and  Section  403.519,  Florida  Statutes,   as  well as  our  rules
implementing   those  sections,   Rules   25-22.080-.081,   Florida
Administrative  Code.   Section 403.519  was  passed  in  1980  as
part  of  the  Florida  Energy  Efficiency  and  Conservation Act
                          jZ - I   -      DOCUM£MT f-Ttf-SEr.-n !-"E

                                          06508  JUN30 82
                                        =PSC-RECOP.DS/REPORT!K3

-------
   ORDER NO.   21491
   DOCKET NO.  881472-EQ
   PAGE 2
                                                                -
   passage in  1973.             "9  Act  ""-"wit  to  its  initial

  determinations'"^ bTinUi.i.".    '*""1 •   "   all°"
                         '
                                            -
  question  If  power  plant yn^  C°nm,fsion   in  deciding   the
          sulied  hi  ,HCal 9enerati"3 capacity  to  be
          Slant    TH/       P^Posed  electrical  power
          of  Vh.     "P°rt may inclu
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 ORDER  NO.   21491
 DOCKET NO.  881472-EQ
 PAGE 3


     AES  has  negotiated  a  long-term contract for  coal  supply,
 coal   transportation   and coal  waste  disposal  with  Costain.
 Additionally,  bark from  the  kraft  mill  will  be  available  to
 supply a supplemental  source of  fuel  approximately  5%  of the
 time.   .Further,   there   are  plentiful   United   States   and
 international  reserves  of   limestone which are  acceptable for
 sulfur dioxide  capture.   AES intends to enter  into a long-term
 contract  for  its  purchase  and  has no  reason to  believe  that
 such  contract  will not  be  easily  obtained  at  a   reasonable
 price.   Thus  we  find that  this project **itll--provide adequate
 electricity to FPL  and peninsular Florida at a reasonable, cost-

 Cost-teff-active' aTternative 1

     The  circulating  fluidized bed boilers are the  first  to be
 constructed in  Florida for the production of electricity.  This
 project is  a  QF pursuant to  our  rules  and  AES has negotiated  a
 contract  at less  than statewide  avoided  cost for  the  sale of
 firm capacity  and energy to  FPL which  falls  within the current
 subscription  limit  of   500  MW.   That  being  the  case,  this
 Commission  has  already  found- the  proposed QF  to,.be« tbft^most
 cost-effective alternative available^*

•Conservation fl

     In previous  QF need determination cases, we have concluded
 that "cogeneration  is  a  conservation ^neeaure*"  In re: Petition
 of  Hillsborough County  for  determination  of need  for  a  solid
 waste-fired cogeneration power plant.  83  F.P.S.C.  10:104, 105
 (1983);  In  re;  Petition of Pinellas County for determination of
 need   for  a  solid waste-fired   cogeneration  power   plant,  83
 F.P.S.C.  10:106,  107  (1983);  In re: Petition by Broward County
 for  determination  of  need  for  a  solid  waste-fired  electrical
 power  plant,  85  F.P.S.C. 5:67,  68 (1985); In  re:  Petition by
 Broward  County  for   determination  of   need  for   a    solid
 waste-fired electrical   power  plant,   86   F.P.S.C.   2:287,  288
 (1986).   We   have   rethought  this  position.   Traditionally,
 conservation  in the  electric industry  has been  thought  of in
 two  ways:  an  increase  in  fuel  efficiency  and  a  reduction in
 demand.   The   first,   increased  fuel  efficiency,   is  a  net
 reduction in the amount of fuel  used to provide the same amount
 of  electricity.   The  second, a  reduction in  electric demand,
 often  peak-hour  demand,  results  in the deferral  of  additional
 plant   construction.    The   legislative   intent    of   FEECA,
 366.80-.85, Florida Statutes,  to  reduce  "the growth  rates of
 electric  consumption  and  weather-sensitive  peak  demand";  to
 increase  "the  overall   efficiency and  cost-effectiveness  of
 electricity and   natural  gas  production  and  use";  and  to
 conserve  "expensive  resources,   particularly  petroleum  fuels"
 reflects  this  understanding  of  conservation.   Section 366.81,
 Florida Statutes.

     However,   as  the  testimony  by Witness  Bakke   indicates,
 there  is  a recognition  in the industry - that>*«og«n»eration does
 not  "conserve"  fuel* In  the  traditional -sense,   it  merely
 utilizes  fuel  to  "deliver  a service  at  the  least  cost."  In
 some instances  the  fuel efficiency  of  a  cogeneration unit will
 be   the    factor   that   makes   a  cogeneration   project    a
 cost-effective  means  of  producing power,   but   that   is  not
 necessarily the  case.   The price of the electricity  produced by

-------
 ORDER NO.   21491
 DOCKET «,. 881472.EQ
 a  cogeneration  Unih
 noncogeneration  unit-*   -C°Uld  be   lower  than
 steam  produced  by tJf nVmply be«use  the  „"«
 Produces  a  oreaf   / QF  and  so^ to the
Conservation Vnd "otj"1 , of   P«fit
 by -«BCAf- «         'denand-sld
                                to
                                                   • comPa"ble
                                                       °C  the
                                                      high and
                                                    reduction
            £S,.«!"«*>« .tiP-l-tlo. entered into by  the

                        e   r.
          nd used  internally inth^Very  boilers
          1H   replace  existing      Paper  min
        Cedar Bay project.
                                             AES
Therefore,  it  is

                        E-f

-------
PAGE 5
         .?»«-»
                                                oj_t



    ORDERED  that  t^7«(






 MW  recovery boiler  oy

 further                                furnished to the
                                           by Section
        ,,„,. nor*. «—••                  emission

     By  ow.*_.«"111»<>r!!lJ±_..uB—'
 this
  (SEAL)




  SBr
                      E-S

-------

-------
          BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION



In re-  Petition for approval of amended ,  DOCKET «,.
cognation agreement between ™?f   !  &a£Ak ii0.  2SS1
Power & Light Company and AES ceaar B«y, ;
Inc.                            	)  ISSUED:    10-23-90

     ^ £ollowing^^nIrT^cIp'ated in the disposition of

this matter:
                         THOMAS M.  BEARD
                           BETTY EASLEY
                         GERALD L. GUNTER__
                       FRANK S. HES3ERSHIj.ri
       oEDJ^EEMS^om^mm^f^^^^1^
       	RVTWF.EN FT-raTHA POWF.R  & LIG"T cunr^	
                        AES CEDAR RAY,  INC.

 BY THE COMMISSION:
                                           -»  -•"
22.029,  Florida Administrative Code.
                         PASE BACKGROUND

„„

                                              ""' '
     On August 10, 1990,  Florida Power
a petition for approval of
Purchase  of  Firm  Capacity
and  Florida  Power & Light
revision  is  necessary  in  order   to
          the AES Cedar Bay facility   in
                                                    Cedar  Bay,  Inc.
                                                   that this second
                                                   to  economically
                                                       FPL requests
                              £-7

-------
ORDER NO.  23651
DOCKET NO. 900686-EQ
PAGE 2
based  on AES Cedar  Bay's financial  stability;  (3)  no  costs in
excess of full avoided costs are likely to be incurred by FPL over
the  initial  term of the Amended Agreement;  (4)  all payments for
energy and capacity made by FPL pursuant  to  the Amended Agreement
may  be  recovered from  FPL's customers;  (5) FPL shall  not be
required to  resell  the energy and capacity  purchased pursuant to
the Amended Agreement to another electric utility as long as their
retention is the best interest of FPL's ratepayers;  and,  (6(the
AmenLd  Agreement is consistent with the  "determination of need
granted  by the Commission by  Order  No.  21491 issued on June  30,
 1989.
      The Commission's current rules on the approval of negotiated
 contracts require the comparison of the contract to^the fPBUff^
 standard offer contract.   The standard offer contract that was in
iffeiF^FThe-time this contract was  entered into was basecI  on a
 1995 500 MW coal unit.  This comparison was provided by AES and the
 Amended Agreement is shown to be below the ^^^Ltttion  FPL
 value of the standard offer contract.  As part of  ^s petition  FPL
 provided a comparison of the Original  and the Amende^Agreement to
 show that the Amended Agreement is pro3ected  to £e  slightly below
 the Original Agreement on  a cumulative present worth ^aslS'   ™®
 fiaures  provided  by AES   and  FPL  coincide  and  are  shown  on
 Attachment A.   We  find that the amendments to the agreement are
 virtually revenue neutral  and are less than the value of applicable
 standard offer contract.

      The  Ordinal  - Amendment stated  that  the initial  .committed
 capacity of toe  facility>vill be "at-least 180 MW ^^^fj*^
 than  2SQ  MW."   This agreement was considered in  concert with  the
 necS  Vi^ination  proceeding for  this  project.   The  Amended
 iareere-1  c-ntains identical language.   At the time  of the  need
 alt^VV:^:." proceeding,   it  was  anticipated  that  the  steam
 r^uVre^s of seminole Kraft would limit the electrical output of
 the ^'"facility to approximately 225 MW.   Since tne ^nguage xn
 the an^deo  T^c-Wr^t aliens  for  a range  of committed capacity
 !£V  fr-  ^  or-ioinal  acrec-ment,   we  find  that  the  Amended
  ^c-ee:::snt~:s'corsis.^nt  with the determination of  need  grantea by
                           to Order Kc. 21

                                              conrract- petition) we
                                              t. ?.)'id.  binding  it-

-------
ORDER NO.    23651
DOCKET NO. 900686-EQ
PAGE 3
                                                           -
           fa)  The   purchase  can  reasonably  be
               expected  to result in the economic
               deferral  or  avoidance  of capac^y
               construction   from  a   statevid0
               perspective ;

           (b)  The  cumulative present worth of  the
               payments    for  firm   energy   and
               capacity  are no  greater than  the
               cumulative  present  value   of  the
               deferral  of the  statewide  avoided
               unit; and

           (c)   The  agreement   contains  adequate
                security   provisions  to   protect
                ratepayers  in the event AES Cedar
                Bay fails to perform  pursuant to the
                terms of the  agreement.


      As previously  stated,  this  Second  Amended Agreement
 for  payments  for Energy  and capacity  which have  ^^^^f
 present value of less than the applicable  standard  offer c°"tract
 The  Second  Amended Agreement appears to contain greater  security
 ;™Hoionc;  for FPL's ratepayers  than the original  agreement.  The


 result in the economic deferral or avoidance of additional capacity
 construction  by  Florida utilities from  a  statewide perspective."
 ^therefore find that this amended  agreement meets the criteria of
 Rule 2^-17.083(2) and that payments for  energy  and capacity made by
      pursuant  to  the Amended Agreement may be recovered from FPL's
  customers .
       Since the agreement (1) contains adequate security for FPL's
  rateoavers- (2)  has a cumulative net present value of  less than the
  amicable' standard offer contract,  (3) is consistent with'the

-------
ORDER NO.    23651
DOCKET NO. 900686-EQ
PAGE 4
determination of need granted by the Commission in Order No. 21491,
we find that the Amended Agreement  is reasonable,  prudent and in
the best interest of  FPL's ratepayers.

     A  finding  that  FPL should  not be  required  to resell  the
capacity  and energy  is  not necessary  or appropriate to  make a
determination concerning the merits of this contract amendment.  As
stated in Order No. 22424 "the question of whether  FPI- 1S J^i^
to resell, and if so,  at  what price, is best addressed by this body
when  such a transaction  takes place  or a substantially affected
person alleges  that such a transaction  should have taken place.

      Based  on  the foregoing,  it is

      ORDERED by  the  Florida  Public  Service  Commission  that  the
petition  filed by Florida Power &  Light  Company for the approval of
the Amended Cogeneration Agreement with AES Cedar Bay, Inc.  should
be and  is hereby granted.  It is  further

      ORDERED  that  this  Order   shall  become  final  unless an
 appropriate petition for formal  proceeding is  received by  the
 Division  of  Records and  Reporting,  101  East  Gaines  Street,
 Tallahassee, Florida 3239S-0870,  by  the  close of  business  on the
 date indicated  in  the  Notice of  Further  Proceedings or  Judicial
 Review.

      By  ORDER  of  ".he  Florida  Public  Service  Commission,  this
   23rd	 day vrf 	 OCTOBER	/  	1120	•
                                   _   TRIBBLE/
                                 Division  of Records  and  Reporting
  (  S  E A  L  )


  RVE
                                 £-10

-------
ORDER NO.    23651
DOCKET NO. 900686-EQ
PAGE 5
        NOTICE OF FURTHER PROCEEDTNGS OR JUDICIAL REVIEW

     The Florida Public Service Commission is required by Section
120 59(4)     Florida   Statutes,   to   notify   par-cies   of   an/
administrative hearing or judicial «vi~ of O«.™ ««» that
is available under Sections  120.57 or 120.68,
 is avalae uner  ec         .         .,
 well  as the procedures and time  limits  that apply.  This notice
 should not be construed to mean all requests for an adninist i«r,.ve
 hearing or judicial review will be granted or result in the relief
 sought.

      The action proposed herein is preliminary in nature and will
 not  become effective or final,  except  as provided by Rule >  25-
 22.029, Florida Administrative Code.  Any P***™ ™°****£*£^
 interests are affected by  the  action proposed by  this order i..ay
 file a petition for  a formal proceeding,  as  provided b* Rule ,o
 22  029U r  Florida Administrative Code,  in the  form provided by
 Rule 25-22 036(7) (a)  and (f ) , Florida Administrative Code    This
 pe^t'on 2m2us\3 be 'received by  the  Director, ^vision of Records and
 Reuorting at his  office at 101  East Games  Street, Tallahassee,
 Florida      32399-0870,   by    the   close   of   business   on
 November 13. 1990 _ -

      in the  absence  of  such a petition,  this order shall  become
 effective on the day subsequent  to the  above date  as provided by
 ^^25-22.029(6) , Florida  Administrative  Code, and as reflected  in
 a subsequent order.

      Any  objection  or  protest  filed in  this  docket before the
 issuance  date  of  this  order  is considered  abandoned unless  it
 satisfies  the  foregoing  conditions  and  is renewed  within the
 specified protest period.

       If this  order  becomes  final  and  effective on  the  date
 described above, any party adversely affected may request judicial
 review by the Florida Supreme Court in the case of  an electric, gas
 or  telephone utility or by the  First District  Court of Appeal  in
 the  case of  a  water  or  sewer utility by filing a notice of  appeal
 with the Director, Division of Records  and Reporting and filing a
 copy  of  the  notice  of  appeal  and   the   filing  fee  with  the
 appropriate  court.   This  filing must  be completed within  thirty
  (30)  days  of the 'effective date of this order, pursuant to Rule
                              e -

-------
ORDER NO.   23651
DOCKET NO. 900686-EQ
PAGE 6
9.110, Florida Rules of Appellate Procedure.  The notice of appeal
must be in the  form specified in Rule 9.900(a), Florida Rules of
Appellate Procedure.

-------
ORDER NO.    23651
DOCKET NO. 900686-EQ
PAGE 7
ATTACHMENT A
                  SUMMARY OF  PAYMENTS PURSUANT  TO
                  FPL/AES AMENDED_CONTRACT_^$_000^

YEAR
1990
1991
1992
1993
. 1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
1995

STANDARD
OFFER ORIGINAL
CONTRACT AGREEMENT
$0
$0
$0
$75,936
$81,947
$74,213
$78,770
$83,655
$88,757
$94,228
$100,054
$106,180
$112,715
$119,921
$127,316
$135,081
$143,376
$152,201
$161,588
$171,513
$182,106
$193,235
$205,183
$217,788
$231,168
$245,370
$260,445
$276,447
<* f\
§0
?o
$65,831
$68,701
$71,776
$75,038
$78,353
$81,873
$85,465
$89,511
$93,094
$96,498
$101,044
$105,660
$110,500
$115,696
$121,249
$126,890
$132,888
$139,395
$146,124
$153,094
$143,357
$150,720
$159,642
$167,468
$176,586

AMENDED
AGREEMENT
$0
bO

$68*, 584
$71,652
$74,906
$78,714
$81,726
$85,310
$89,347
$92,922
$96,320
$100,854
$105,460
$110,288
$115,471
$121,009
$126,637
$132,620
$139,109
$145,320
$152,772
$143,015
$150,355
$159,249
$167,051
$176,140
         NPV (1990)   $805,811
         $670,926
                                                  $669,648

-------

-------
           APPENDIX F

FEDERAL AVIATION ADMINISTRATION
   RESPONSE TO FAA FORM 7460-1

-------

-------
03-29-1993 15:58    9047511008              CEDAR BAV                          p. 02
   HSS222J2L                            RoutfwrnlUolon            P.O. Box20638
   ottanspcrtoiion
   Federal Aviation
    Mr* Kerry VorKonda
    Plant Manager
    AEB Cedar Bay, lac,
    9469 Eactport Road
    Jacksonville, PL  3221B

    Dear Mr. VorKonda!
    We have  completed  a feasibility atudy  which determined that an  instrument
          p^n^T CI/P) t0 the Jack"nvme International Ai?£rti. feasible?
            wallftA"d °*.r°2r pr%°Acd non-federal nondirectional radio beacon
          as submitted on PAA Pom 7460-1, dated August 9,  1991, and  the  latest
              .Sclosed!     t0ber "'  1W1* - A «W of  the respon.; to the .xeSSed
    Yon are authorited I to proceed with the establishment of the facility.
                         V3 «h,°,uld4^  »«« M a reference for Jitin«7and
                          *«t«"«ti«»of this facility may chan8e your obligations
                                             » and
          i!           .i»               r      *0 -
    Also,  revision of  the  airport layout  plan  may be necessary.   For  further
    information, contact the Orlando, Plori da .Airports Di strict 'Office at (407) W8-
                    tech"lclant «** |a« • concept and performance examination  to
             to Bake •rruvemenci for the txuinatioiu and in.pectlon.

                     SS*]«tlMI '"ttlt« '" »" technician and confltMtloi. ly APS
                                             *•
   Sincerely,

        i» -^-^
    .
   K.  8.  Imsand
   Manager,  Resource and Planning Branch

   Enclosure

   eet
   Mr. Pete  Norgeot
   11401 Lanar  Location P6B4
   Overland  Park, KS  66211

-------
      03-29-1993 15:55    904751100B
*.   &0 NOT REMOVE CARBONS
                                             CEDAR BAY

                                                                             P. 03

                                                                    FormAppmnaoua Wo. 212MCKH
                      NOTTCEOFPROPOSEDCONSTRUCTWNORALTERATION   \^<""tt^Hu
                                                             	91>ASO-1842-Qg
                                                          t. CempMt Ditariptten of Stnwtura
                                    (XW«kBcMrf«0*IM'
                                     tKlftnfa.Ja^i^y.y  1ppp
       •
               Cedar Bay, inc.
                      le, PL. 32218
                                                    "I
               l«ii««CHrifT«M,Mfl«-.
                 ikaom    	
                 Within City7
                                                                  MnH(iMlM
                                                             Twintea Antenna for
                                                            Nondlrectional  Beacon
                                                                                  1 R
                                                                                  60
                                 	^szsssassti^^
              See Prior Subaittala ret  Aeronautical  Study f  88-ASO-1414-OE
             	.	.              ^^              *  91-ASO-1414-OE
                ••"—•• "»w *i mm tuni NCUM         ^^^^^^
                 Kerry VarXonda. ni»n»  Manac
                                                              ^
f*A Form 7440-1 (4«}aUPEm£DES PREVIOUS HXTIOM

-------
            APPENDIX G

        FLORIDA DEPARTMENT
   OF ENVIRONMENTAL REGULATION
REVIEW OF THE PROPOSED MODIFICATION
 OF CERTIFIED ELECTRIC POWER PLANT
               SITE

-------

-------
;Olj  Florida  Department of Environmental Regulation
        Twin Towers Office Bldy. • 2600 Blair Stone Road • Tallahassee, Florida 32399-2400
           i Chiks. Governor
                               March 25,  1993
 Mr. Robert T. Bent on, II
 Division of Administrative Hearings
 The Desoto building
 1230 Apalachee Parkway
 Tallahassee, Florida 32399-1550

 Re:  Cedar Bay Cogeneration Project,  PA 88-24A
      DOAH Case No. 88-5740 EPP

 Dear Mr. Benton:

 Enclosed, please find a copy of the Department of
 Environmental Regulation's Review of the Proposed
 Modification of Certified Electric Power Plant Site for the
 Cedar Bay Cogeneration Project.
                               Sincerely,
                               Hamilton S. Oven, P.E.
                               Administrator, Siting
                               Coordination Office
 cc:  All Parties

-------

-------
STATE OF FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION
          REVIEW OF PROPOSED MODIFICATION OF
          CERTIFIED ELECTRIC POWER PLANT SITE
                          FOR
            CEDAR  BAY COGE^ERATION PROJECT
                   CASE NO. PA  88-24A
              Siting Coordination Office
                Office of the Secretary
                 Tallahassee, Florida
                    MARCH 25, 1993
                       Gr-3

-------

-------
                      CERTIFICATE OF SERVICE
    I DO HEREBY CERTIFY that a true and correct copy of the
foregoing document has been sent by U.S. Mail or by Hand Delivery
to the following listed persons:
Terry Cole, Esq.
Scott Shirley, Esq.
Oertel Hoffman Fernandez & Cole
P O Box 6507
Tallahassee FL  32314-6507

Lucky T. Osho, Esq.
Department of Community Affairs
2740 Certerview Dr
Tallahassee FL  32399-2100
Jim Antista, General Counsel
Florida Game & Fresh Water
  Fish Commission
620 S Meridian Rd
Tallahassee FL  32399-1600
William C. Bostwick, Esq.
2034 University Blvd W
Jacksonville FL  32217-2016
Nikki Clark, Esq.
The Capitol, Rm 210
Tallahassee FL 32399-0001
Lawrence N. Curtin, Esq.
Holland & Knight
P O Drawer 810
Tallahassee FL  32302
 Gregory K. Radlinski,  Esq.
 City  of Jacksonville
 600 City Hall
 220 E Bay  St
 Jacksonville FL   32202

 M.B.  Adelson,  IV,  Esq.
 Assistant  General Counsel
 Douglas Bldg MS-35
 3900  Commonwealth Blvd
 Tallahassee FL  32399-3000

 Rob Vandiver,  General  Counsel
 Mike  Palecki,  Chief
 Bureau of  Electric & Gas
 Florida Public Service Comms
 101 E Gaines St
 Tallahassee FL  32399-0850

 James A. Heard,  Esq.
 4741  Atlantic  Blvd
 Suite C
 Jacksonville FL   32207

 Rufus Pennington, Esq.
• Margol- &• Pennington -
 76 Laura St, Suite 1702
 Jacksonville FL   32202

 Raymond Ehrlich,  Esq.
 Holland &  Knight
 2000  Independent Sq
 Jacksonville FL   32202

-------
Certificate of Service  (continued)
Wayne E. Flowers, Esq.
General Counsel
St Johns River Water
Management District
P O Box 1429
Palatka FL 32178-1429
                      Gary P. Sams, Esq.
                      Julie B. Rome, Esq.
                      Hopping, Boyd, Green & Sams
                      P.O. Box 6526
                      Tallahassee FL  32314
this
day of March, 1993.
                                  STATE OF FLORIDA DEPARTMENT
                                  OF ENVIRONMENTAL REGULATION
                                                             r\
                                  RICHARD T. DONELAN, JR.
                                  Assistant General Counsel

                                  Twin_Tavters ..Of £ice..Bldg.
                                  2600 Blair Stone Rd
                                  Tallahassee FL  32399-2400
                                  Telephone:  904/488-9730

-------
PA 88-24A
     CEDAR  BAY  COGENERATION PROJECT MODIFICATION ANALYSIS

                         INTRODUCTION

    This document is the official report and recommendation of
the Department of Environmental Regulation to the Siting Board
concerning proposed modifications to the conditions of site
certification for the AES Cedar Bay Cogeneration Project,
issued February 18, 1991, to AES Cedar Bay, Inc. (AES) and
Seminole Kraft Company  (SKC).  By order of the Board dated
June 16, 1992. a proceeding concerning modification of the
certification was instituted in lieu of a proceeding to revoke
the certification for the reasons stated in the Order.

    The basis of the modification proceeding is a set of
proposed changes to the  original conditions of certification
tendered by AES and SKC  to the Siting Board.  These changes
were tentatively accepted by the Siting Board, subject to
technical  review and verification by the Department and other
agencies having jurisdiction over the project in accordance
with the procedures of  the Florida Electrical Power Plant
Siting Act (PPSA), §403.501 et seg., Florida Statutes.
Pursuant to the procedures of Section 403.508(3), Florida
Statutes,  the  Department has evaluated the proposed
modifications  to the conditions of certification contained  in
the AES-SKC Petition for Modification dated July 7, 1992, as
further refined at the  suggestion of the current Project
manager for the Cedar Bay Cogenerationgta^ect^JCBCP), the  U.
S. Generating  Company  (USG) ;  onfcarciriS, 1993J an amended
Petition for Modification was filed whicn  requests formal
recognition of the fact that the AES Corporation is no  longer
associated with the control  of the CBCP, and that the name  of
the  corporate  entity which holds the certification has  been
changed.

     Based  on  its  review and  evaluation the Department  is  able
to conclude that  the proposed modifications sought by the
holders of the site certification  for the  CBCP  are both
technically feasible and consistent with the non-procedural
standards  of  the  agencies of jurisdiction.  More  importantly,
the  Department is also  able  to conclude that,  if the  existing
site certification for  the CBCP  is amended to  incorporate  the
modified  conditions of  certification which are  appended to
this Report,  there will be beneficial renneticms  in  thp ,
adverse *»**"*•*"?TnHPn.f'P>^  -imparts  of the  CBCP  compared either "to.
t-Ke  impaeETof the facility  as  originally  certified  or to the
Tinpii nf.B evpfected trom the continued-UptadLlun Ut  the bKL paper
mill witnoiit  the -certified power Plant.   Consequently,  the
Department'is prepared  to recommend that the  Siting  Boara
 impose the modified conditions of certification and allow the
certificate holders to complete construction and undertake
operation of  the facility in accordance with the modified site
certification.


                               1

                           Gr-7

-------
  PA 88-24A


      In the interim since the  institution  of the modification
  proceeding,  AES Cedar Bay,  Inc.,the  Delaware  corporation which
  exercises primary responsibility  for the  construction  and
  operation of the certified  power  plant has undergone a change
  in ownership and of name:   as  of  December 19D2, officials of
  the AES companies no longer exercise control  of the
  corporation and,  as cf March  1993, the name of the corporation
  has been changed to Cedar Bay  Coqer.eration. Inc.  The
  Department recommends,  and  the Department's recommended
  conditions of certification have  been revised to so reflect,
  that the conditions of certification be modified to show the
  correct corporate name .of the  certificate holder. Such a
  modification will also evince  official recognition that the
  CBCP is now under the supervise op of controlling in^cT-o^tp
  different from those respcnsiVOp  fnr arsons  uhich were- r^grnorf
  to^Save undermined public confidence in the site certific*+i™
  process.                                     "	.

      The Department's technical evaluation of  the proposed
  modifications is  set forth  below. Issues  related to water and
  air emissions are discussed separately.   Attached is a
  compilation  containing modified conditions of certification
  which the Department believes  are legally sufficient to
  implement the terms of the  proposal  made  by the certificate
  holders to the Siting Board while safeguardino the public
  interests protected by the  Power  Plant Siting"Act.


  I.   WATER ISSUES

  A.  The Questions  of Cooling Water and Waste Water Discharge

      During the original  certification proceedings, the Siting
  Board determined  that the consumptive use of  potable ground
  water for cooling was not in the  pub-l-io interest and
  prohibited the use of water water withdrawn from the Floridan
  Aquifer fcr  cooling purposes.  See Condition  IV C. The Board
  directed  AES  to explore  the use of treated waste water or
  water from the St.  Johns River to cool the steam condensers.
  After evaluating  several options, in August of 1991, AES first
  proposed  to use treated wastewater from the converted  SK
  recycled  fiber paper mill.  The questions of what method of
•  cooling the CBCP's  steam turbines, and what,   if any, waste
 water  discharges were to be allowed from the CBCP were not
 resolved  prior  to  the Siting Board's action to initiate the
 modification proceeding.  Consequently,  in its settlement
 offer, AES proposed to implement a wastewater treatment and
 reuse  system that would require no discharge of industrial
 wastewater from the CBCP, while utilizing treated waste water
 originating from SK's process to provide cooling water for use
 by the CBCP and SK.

     The conceptual approach to cooling water supply and
 wastewater treatment proposed by AES has been refined and



                            G--S

-------
PA 88-24A


clarified.  As currently evaluated,  the CBCP water system
includes a cooling tower makeup treatment system designed to
treat 5500 gpm supplied from three sources:  from the Seiainole
Kraft wastewater system, from the CBCP stormwater runoff
control ponds, and from various internal, low volume waste
streams (e.g. floor drains) generated by the CBCP.  A
conventional lime-soda water treatment system will be utilized
including f eT"»"i? chloride ^as a coagulant in conjunction with a
reverse osmosis and brine concentation/crystalization system.
By evaporation and solids removal, the treatment system will
eliminate up to 40% of Seminole Kraft's existing  wastewater
discharge volume.  In addition, CBCP will provide Seminole
Kraft with up to 500 gpm of treated water for use in its
cooling tower.

    This system has several environmental benefits.  It
eliminates all industrial wastewater discharges from CBCP.
There is no longer a need for any variance to water quality
standards in order to allow operation of the facility.  The
elimination of up to 40% of the SK wastewater discharge
because of waste water reuse will eliminate up to 40% of SK's
permitted wasteload to the St. Johns River.  The CBCP water
treatment system will eliminate almost all potential for
discharge of stormwater from their site.  Stormwater will
discharge only as a result of extreme rainfall events, only
when the pumps from the stormwater ponds to the treatment
system or emergency water storage tanks are unable to remove
or retain all the excess stormwater prior to overflow.  The
stormwater control system is designed to prevent discharge of
stormwater from the coal pile/materials storage area from
rainfall events up to sn-year, 24-hour storms.

    CBCP's furnishing SK witn up to 500 gpm of its own treated
waste water for reuse in the cooling tower reduces SK's need
to use potable water, thereby further conserving this vital
resource in accordance with the intent'of the Siting Board's
original certification decision.

    In the future, if SK improves the efficiency of their
recycled paper process, it may further reduce the volume of
its wastewater available for use by CBCP. By the use of
conservative design techniques to account for a potentially
lower future volume with higher concentrations of chemical
constituents, the proposed system has been configured so that
it is capable of proper function even if SK reduces the volume
of its wastewater. In this eventuality, the CBCP treatment
system will eliminate a larger percentage of the SK discharge
than currently contemplated.

    The proposed CBCP cooling tower pretreatment/wastewater
treatment system will produce sludges that will have to be
dewatered and sent to a solid waste landfill for disposal.
The CBCP water treatment system will be built to the south of
the boilers on a cleared portion of the certified site.

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 PA 88-24A


     The construction methods at the CBCP site were altered to
 eliminate the need to discharge water produced by dewatering
 of excavations.  Therefore, existing conditions of
 certification  (Condition III 12) concerning construction
 dewatering are superfluous and should be eliminated or
 modified to reflect the avoidance of dewatering discharges.

 B. Conditions of Certification for Zero Discharge System

     The proposed zero discharge/wastewater treatment system
 will eliminate a number of the discharges previously allowed
 by the existing conditions of certification.  The elimination
 of the discharges reduces the adverse environmental impacts of
 the CBCP.  The following discharge streams and their
 authorizing conditions should be deleted or modified:
      III.A. Plant Effluents and Receiving Body of Water

      2.  POD - Change to Broward River only
      3.  Thermal Mixing Zones - Delete.  No discharge.
      4.  Chemical Wastes - Modify.  No discharge.
      5.  pH - Modify. Storm water only.
      7.  Cooling Tower Slowdown - Modify. No discharge for
          CBCP.  Keep 7.d. re SK shut down.
      8.  Combined Low Volume Wastes - Modify.  No discharge.
      9.  Metal Cleaning Wastes - Modify.  No discharge.
     11.  Boiler Blowdown - Modify.  No discharge.
     12.  Construction Dewatering - Modify.  No discharge.
     13.  Mixing Zones - Delete dewatering. No discharge
          Modify for stormwater if needed.
     14.  Variances - Delete.  Not needed.

    The zero discharge system was presented as Phase I of a
proposal for consideration of the CBCP's treating all of SK's
waste water.  Phase II of the proposal was made contingent
upon the CBCP's obtaining from the  U. S. Environmental
Protection Agency an NPDES permit and a conclusion by the
Department that CBCP's treatment and discharge of all of
Seminole Kraft's and CBCP's wastewater would result in a net
environmental benefit compared to the zero discharge system.

     The Department's technical evaluation indicates that
implementation of the Phase II option is .not likely to
result in any net environmental benefit, especially when
compared to the demonstrable benefits of the zero discharge
system. Evidence has been presented which discloses that the
expected Phase II discharges to the St. Johns or Broward
Rivers could forseeably violate water quality standards for
certain metals. 1 Discharges that violate standards are not
allowable unless a variance can be granted in the public
interest.  The requirements for granting a variance contained
in Section 403.201, F.S., can not be met since the proposed
zero discharge system is practical and affordable for the
CBCP.I  The Department does not recommend that the CBCP be
required to pursue a discharge option that could result in

                               4

                            Cr "10

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 PA 88-24A


violations of water quality standards.   The zero discharge
system offers concrete environmental benefits which would not
be available under the Phase II option.

 II.   AIR ISSUES

 A.  Introduction:  The Question of Steam for Seminole Kraft

      By deciding to make fundamental changes in the paper
 making process at the SK paper mill, the steam host for the
 CBCP, Seminole Kraft Corporation created substantial
 uncertainty as to the basic assumptions on which the CBCP was
 originally certified.  During the course of the certification
 proceedings, SK decided to convert its  mill from a Kraft
 pulping process, by which raw wood pulp is converted to paper
 by chemical treatment,  to a process which makes paper from,
 recycled cardboard boxes without the need for the kraft
 process.  This change eliminated the need for the new
 Chemical recovery boiler, integral to the kraft system but
 unnecessary for the recycled paper process,  for which SK had
 received a construction permit in 1990  from the Department.

      SK's decision to forgo the new recovery boiler
 eliminated its expected  emissions of air pollutants and
 eliminated its potential demand for the use of ground water
 as part of chemical solutions and for cooling.   However,  the
 elimination of the new recovery boiler  system,  coupled with
 the mandated retirement of the existing SK chemical recovery
 boilers as a result of regulatory enforcement action,  caused
 a  substantial reduction in SK's ability to self-generate
 steam compared to its previous capability.   In addition,  five
 antiquated SK power boilers—three oil-fired and two
 bark-fired—were to be shut down to provide emission offsets
 necessary to allow the permitting of the proposed CBCP.

      The question of what,  if anything-,  SK intended-to do
 regarding its self-generated steam deficit was not
 forthrightly addressed by the applicants during the
 proceedings which led to the issuance of the CBCP
 certification.   The site certification  application (SCA)
 stated that the CBCP would generate 225  MW "f elerr.irjty for
 Florida Power and Light (FPL)  and supply \640,000 Ib/hrSof
 process steam for SK. SCA,  p.  ii.  In addition,  the SCJr
 proposed the shut down  of the old chemical  recovery boilers
 and all five power boilers operated by SK to supply steam for
 use at the  mill.   Based on the record of the certification
 proceedings for CBCP, there was no basis for a  conclusion
 that  all SK's steam needs would not be supplied by the CBCP.
 Retirement  of the existing power boilers at  SKC,  substantial
 air pollution sources,  was expected to contribute to
 improvement of  ambient  air quality,  even with the addition of
 the emissions of  the coal-fired CBCP.
                           G -

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 PA 88-24A
      The manner in which the applicants for certification
 attempted to resolve the steam deficit in SK's favor was a
 substantial or motivating cause of the certification crisis
 of spring 1992.  The modifications as to air emissions
 proposed by the certificated parties to resolve the crisis
 are primarily aimed at securing the fundamental assumption on
 which approval of the cogeneration facility rested:  that the
 level of air emissions permitted for the CBCP would support
 a volume of steam sufficient both for commercial electric
 power generation and for commercial use by the papermill in
 its recycling process.

        The first expedient adopted by SK to address its steam
 deficit was to seek Department permits allowing continued
 operation of its five old boilers,  notwithstanding the fact
 that the boilers in question were required to be shut down
 under Condition II D of the site certification.   During the
 investigation which culminated in the Board's order of June
 16,  1992, it was disclosed that AES and SKC had entered into
 a contractual agreement relating to continued operation of
 the boilers in question after the CBCP began commercial
 operation.   The circumstances of this disclosure had a
 substantial bearing on the Siting Board's May 5,  1992,  vote
 in favor of revoking the CBCP certification.

      In the Department's opinion,  continued operation of the
 old boilers is unacceptable for two reasons.   First,
 continued operation of the old boilers following start-up of
 the CBCP power plant would negate a large portion of the air
 quality improvements produced by the CBCP and would be
 directly contrary to the intent of  the site certification.
 Second,  due to the age,  inefficiency,  and low stack heights,
 the  old boilers are predicted to continue contributing to
 violations  of ambient air quality criteria.   If  the CBCP is
 not  allowed to enter commercial operation because of
 revocation  of the certification  or any otligfcreason that
 would relieve SK from the obligations  of CdncHLlJion II D,  the
 result  would be unfortunate from an envir
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 PA 88-24A
 alone was allowed under the original conditions of
 certification.  In addition, as proposed, the plan places an
 enforceable ceiling on emissions from SK's forseeable future
 steam generation needs:  a matter not addressed by the
 original certification.

      Seminole Kraft filed applications with the Department
 for permits allowing them to construct the three new package
 boilers on November 24, 1992.  The Department's review of
 that application should be complete prior to initiation of
 the April hearings on the CBCP.  The Environmental Protection
 Agency indicated on January 15, 1993,  that they had no
 adverse comments on the SK application.

      In order to determine whether the proposed modifications
 actually accomplish their stated purpose, the Department has
 reviewed extensive technical information supplied by the
 certificate holders,  including engineering data and computer
 modeling of expected air impacts from the CBCP and the new
 gas-fired SK boilers.   In particular,  the newly-performed
 computer modeling provides an unprecedented level of detail
 and scope as expected ambient and regional air impacts;   the
 air emissions modeling previously submitted by AES in
 connection with the SCA do not form the basis for any
 technical conclusion in this report.

      The Department's  overall evaluation of the expected
 impacts of the combined emissions of air pollutants from CBCP
 and SK as now proposed substantiates that the improvements in
 ambient air quality impacts which were projected before  the
 CBCP was certified will be attained even if SK is allowed to
 construct new gas-fired power boilers.   Because of reductions
 in expected actual emissions due to implementation of new
 nitrogen oxide (NOX) control technology and use of lower
 sulfur coal at the CBPC and full-time  gas usage at the new SK
 Boilers,  actual reductions in emissions levels,  compared to
 the originally certified project,  are  likely to exceed those
 modeled.   The basis for the Department's technical
 conclusions is set forth below.

 B.   Ambient Air Quality Analysis

      The Department analyzed the potential  impacts of the
 revised CBCP/SK complex on air  quality  utilizing data
 made available through  EPA-approved atmospheric dispersion
 modelling techniques.   Use of such  mathematical dispersion
 models  allows  the  Department, via different  computer-
 generated cases, to establish comparative differences in
 potential  ambient  air quality impacts caused by different
 plant configurations and  levels  of pollutant emissions.   Each
 case has  been  assessed  on  the basis of  the  "worst-case
 scenario," that  is, by  assuming  emissions of the maximum
permitted  levels of pollutants for the plant configuration
under review.  Further, the expected impact  of  each case  on
                           G-13

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 PA  S8-24A


 overall area emissions  is also judged against the backdrop of
 existing regionc.1 emissions based upon the maximum allowable
 emissions  for each existing source identified in the
 regional inventory of individual pollutant-emitting
 facilities.  AM analyses also assume identical "worst-case"
 meteorological conditions.  Five cases were considered.

     The first two cases considered were alternative
 assessments of the impacts of SK's existing "old boilers."
 These are the three oil-fired and two bark-fired power
 oilers.  Although these boilers are required to be shut down
 undar the exsting certification, they are currently in
 operation; si; holds Department permits allowing these boilers
 to  operate until the CBCP commences compliance testing.  If
 the CBCP facility does not commence operation, these boilers
 will remain part of the status quo of permitted sources and
 would continue to impact air quality as allowed by existing
 permits.  Alternative modelling analyses for these sources
 assumed different total annualized steam production rates for
 the aggregate of the five boilers:  the first case assumed a
 rate of 640,000 Ib/hr,  and the second a rate of 745,000
 Ib/hr.

     The third case examined was that of the CBCP operating
 under the existing conditions of certification.  This
 analysis  carried the assumption that the five SK "old
 boilers," having been shut down as required, were no longer
 in operation.

     The fourth case considered was that of the CBCP, as
 proposed to be modified, including the operation of the new
 SK gas boilers.  The base assumption was that the CBCP was
 generating electricity and supplying steam at a rate of
 380,000 Ib/hr to SK, with the three new SK boilers burning
 distillate oil or natural gas and producing 260,000 Ib/hr of
 steam.  The fifth case assumed a-similar- scenario-, except
 that the three new SK boilers were assumed to be operating at
 a steam rate of 375,000 Ib/hr.  In each of these cases the
 "old boilers" were assumed to be inoperative.
     Three comparative assessments were made:

          Assessment A:  Case 5 vs. Case 3

          Assessment B:  Case 4 vs. Case 1

          Assessment C:  Case 5 vs. Case 2

 C.  Assessment hethodology

     The air quality impacts were modeled for five pollutants
 for which there are ambient air quality standards - sulfur
dioxide/S02,  particulate matter/PM-10, nitrogen dioxide/NC>2,
carbon monoxide/CO and Lead/Pb and an aggregation of trace
pollutants.   Ground level concentrations were predicted for

                              8

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   PA  88-24A


   1008  locations on  a polar grid extending out ot 25 kilometers
   from  the site.  A  total of 720 receptor locations were
   located within 3 miles of the of the two facilities.

        For each Assessment  (A, B, and C), three comparisons
   were  made.                                       *


      First, the maximum predicted concentrations for each
 pollutant were modeled.  These concentrations were modeled at
 all receptors and for each applicable averaging periods.
 Concentrations at each receptor were compared between cases.

      Second, the maximum predicted concentration for each
 applicable averaging period  was identified at each receptor.
 Any increase or decrease in impact was noted.

      Third,  for each case associated with the modifications
 proposed for the CBCP,  the total number of receptors where air
 quality would be improved was determined.

 For Assessment B,  the analysis set above was performed with
 the impacts of Case 1 subtracted from the impacts of Case 4.
 For Assessment C,  the same analysis is performed with the
 impacts of Case 2  subtracted from the impacts of Case 5.

 D. Findings

 1. Case Comparison.

                Assessment  A  (Case 5 vs.  Case 3)

      The maximum predicted impacts of Case  5 (revised CBCP
 plus  new SK  gas boilers at maximum steam  rate) are  lower than
 those of Case  3 (CBCP as certified).   For S02, the  average net
 regional S02 air quality effect  of Case 5 indicates a small
 net improvement with Case  5  over Case 3.  For all other
 substances except CO and annual average PM10,  the average net
 regional air quality effect  of Case  5, although  not
 significant, is also positive.

      For CO, the average net air quality effects are  negative,
 with  a  minority of receptors showing  improvement.   However,  it
 is important to note that the maximum CO impacts for  both
 cases are much  less  than Florida's and EPA's Significant
 Impact  Levels  (SILs) for 1 hour CO and 8-hour CO
 concentrations.

     For annual average PM10 concentrations,  although the
maximum concentrations are lower, the net air quality effect
on a regional basis  is negative.  The average net effects are
much less than the annual PM10 Significant Impact Level.
Thus, the net effect is insignificant.
                            G -

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 PA 88-24A


     Table 2-14 (see Appendix B)  displays the findings for
Assessment A for SK's package boilers firing natural gas at
maximum steam rate.  Results are shown for CO and N02 only,
since these are the only emissions that increase in Case 5,
due to the package boilers firing natural gas.  On balance,
the air quality impacts of the CBCP in terms of maximum
impacts, as proposed to be modified, and the addition of any
boilers on the SK site at the proposed capacity of 375,000
pounds per hour of steam, will be less than the air quality
impacts of the CBCP as now certified, although net regional
differences are small.

            Assessment B  (Case 4 vs. Case 1)

     Tables 2-15 and 2-16 indicate that the regional net air
quality effect of Case 4 (CBCP as modified plus new SK boilers
at average steam rate) is positive, although not significant
for all pollutants and averaging periods.  This indicates that
a small average net benefit to air quality over the entire
model receptor grid can be expected.  On balance, the air
quality impacts of the CBCP, as proposed to be modified, and
the addition of the three proposed boilers on SK's site
necessary to provide 640,000 Ib. of steam per hour for SK's
use will be less than the air quality impacts of SK's future
recycling operation using SK's existing boilers without the
CBCP.

           Assessment C  (Case 5 vs. Case 2)

     Tables 2-17 and 2-18 indicate that the net air quality
effect of Case 5 is positive for each emission and averaging
period, although not significant for some pollutants.  This
indicates an average net benefit to the air quality.

     On balance, the air quality impacts of the CBCP, as
proposed to be modified, with the addition of the new
gas-fired steam boilers on the SK site at their maximum
allowable emission rates, will be less than the air quality
impacts of the maximum allowable emissions of SK's recycling
operation with the "old boilers" as presently permitted.

2.  >m>»ient Air Quality Standards  (AAOS) Analysis

     The results of the modeling for the CBCP alone, as
proposed to be modified, are presented in Tables 3-24 through
3-28 for the pollutants CO, N02, PM10, Pb, and SO2.  Each
table lists the maximum predicted impact of the CBCP for each
applicable AAQS.  The significant impact level  (SIL) is also
listed for the applicable pollutant.  The predicted impacts
for CO are below the SILs.  Therefore, CO was eliminated from
further consideration, since the CBCP can neither cause nor
contribute to an AAQS violation for CO.  Lead concentrations
were also found to be insignificant.


                               10

                             Gr-lfc

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  PA 88-24A
      The remaining pollutants  (PM10,  N02  and  SO2),  were
 modeled for the CBCP,  SK's  package  boilers  and  all  the other
 existing and permitted sources  for  each pollutant in the  area.
 Monitored background concentrations for each  pollutant were
 added to the model's predicted  concentrations to obtain the
 total predicted concentration.  This concentration was compared
 to the respective AAQS.   Based  on this analysis, it can be
 concluded that the CBCP,  as proposed  to be  modified,  would
 neither cause nor contribute to a violation of  the  respective
 PM10,  N02,  or S02 Ambient Air Quality Standards.

      The CBCP also emits  volatile organic compounds (VOC),
 which can be precursors to  ozone formation.   There  are no
 acceptable modeling techniques  for  assessing  an individual
 source's impact on ozone  levels due to uncertainties
 concerning the photochemical processes for  ozone formation.
 Accordingly,  no single source modeling is required  by either
 EPA or DER.   Under any circumstances, however,  no significant
 impact on ozone concentrations  from the CBCP  is expected  since
 the VOC emissions of the  CBCP will  be more  than offset by
 shutdown of  the SK "old boilers," which are current VOC
 sources of  significance.

 3.  Increment Consumption Analysis

     The results of the maximum predicted SO2 Class I and
 Class  II Prevention of Significant  Deterioration (PSD)
 increments consumed by the  CBCP itself were evaluated.  The
 maximum S02  impacts of the  CBCP by  itself exceed neither
 the Class I  nor Class  II  allowable  increments.

 An  analysis  was performed to identify the maximum total Class
 II  increment  consumption  by all PSD increment consuming and
 expanding sources  (including SK'& package.,boilers, as .increment
 consuming sources)  to  which the CBCP  would  contribute more
 than the Class  II  SILs.   None of the  total  concentrations
 exceeds  the  Class  II PSD  increments,  where  the  CBCP has a
 significant  impact.  Thus,  it can be  concluded  that the CBCP,
 as  proposed to  be  modified,  would neither cause nor contribute
 to  a violation  of  the  PSD Class  II  S02 increments.

     For the  Class  I area, the  total  SO2 increment  consumption
 due to all increment consuming  and  expanding sources  was
 identified for  each averaging period,  modeled year  and Class I
 area  (Wolf Island Wilderness Area and Okefenokee Wilderness
Area).   Based on these results,   it  can be concluded that the
 CBCP,  as proposed to be modified, would neither cause nor
 contribute to a violation of the Class I SO2 increments.
                               11

                            Gr-  I?

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  PA 88-24A


      A similar analysis was performed  for  Total  Suspended
 Particulates/PM10/(TSP).   None  of  the  total  concentrations
 exceed the Class I or Class II  PSD TSP increments.  Thus, it
 can be concluded that the C3CP,  as proposed  to be modified,
 would neither cause nor contribute to  a violation of the PSE
 Class I or Class II TSP increments.

      A similar analysis was performed  for  NO2.   None of the
 total concentrations exceed the Class  I or Class II PSD NO2
 increments.   Thus,  it can be concluded that  the  CBCP, as
 proposed to be modified,  would  neither cause nor contribute to
 a violation of the PSD Class I  or  Class II N02 increments.

 4.   Air Toxics Analysis

      The air toxics emissions from the CBCP, by  itself, as
 proposed to be modified,  were modeled  to determine the maximum
 impact of each pollutant  for each  averaging  period for which a
 draft No Threat Level (NTL)  has been proposed.   The results
 were evaluated.   In each  case the  impacts  are below the draft
 NTLs.

      The Department has been working with  EPA and their
 consultant to have  a risk assessment made  for emissions from
 the CBCP.   The results of that  study are not yet available.
 Preliminary indications are that due to the  shut down of pulp
 mill sources,  the CBCP will have a  negligible impact on human
 health.   By replacing SK's bark  and power  boilers, the CBCP
 and SK package boilers may provide  a slight  net  health benefit
 since the cancer  risks of the CBCP plus package  boilers are
 less than the risks posed by the existing  SK facility.

      A preliminary  ecological risk  assessment indicates that
 the revised  CBCP  and SK package  boilers will not pose a
 potential  risk to aquatic or terrestrial environments^ . Due.to.
 the elimination of  heavy  oil containing vanadium from the old
 SK  power boilers, the revised facility  will  likely present
 less  of  an ecological risk than  the old pulp mill.

 5.   Supplemental  Analyses

     A.  Impact  of Secondary Emissions -

     No  significant  adverse air  quality impacts  are expected
 from secondary emissions  associated with any residential,
 commercial,  or industrial  growth directly related to the
 construction or operation of the CBCP.

     B.  Impacts of the CBCP  on Soils and Vegetation -

     Comparisons were made  of the combined impacts of the CBCP
and SK's package boilers with those of  SK's existing power and
bark boilers  in future recycle operation.   Those comparisons
clearly showed that there would  be a net regional improvement

                              12

                             Gr- 12

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  PA 88-24A


 in maximum concentrations of S02,  N02 and CO.   Since SK's
 power and bark boilers are to be retired when  the CBCP begins
 operation, and since the conversion to recycles paper
 eliminates the chemical recovery boilers, smelt dissolving
 tanks and lime kilns, it can be concluded that the impacts (if
 any)  of these substances on vegetation will be decreased.

      C. Visibility Assessment -

      The emissions from the proposed facility  were shovn to
 have  an insignificant impact on visibility at  both the
 Okefenokee and Wolf Island Class I areas.  The potential for a
 visible plume from the CBCP is expected to be  localized
 (within 5 km)  and occur only under light wind,  neutral
 dispersion conditions which occur  primarily during early
 daylight hours.

      D. CBCP Cooling Tower Impact  Analysis -

      The potential for fogging or  icing conditions on nearb^
 routes to be caused by the CBCP's  cooling towers and salt
 deposition rates due to cooling tower operations was
 evaluated.  The applicant used the SACTI (Season and Annual
 Cooling Tower Impacts)  model to make this evaluation.   The
 analysis indicates that,  based on  the low probabilities
 predicted by the SACTI model,  the  visibility reduction due to
 the CBCP's cooling tower is not expected to pose a threat to
 local transportation routes.   The  effects of salt deposition
 on local vegetation is not expected to be significant.

      E.  Screening Modeling Analysis for Low Load CFB Operation

      A screening modeling analysis was conducted to compare
 four  operating scenarios  for the CBCP's CFBs.   The purpose of
 this  analysis  is to evaluate the potential  for  CBCP operation
 at low load conditions to cause-higher total-ambient-impacts-
 than  operation at maximum load.  The load conditions  modeled
 were  100%,  67%,  40%,  and  17% of full load.

      The results of the ISC modeling analysis for each
 meteorological condition  and load  case demonstrate that the
 maximum normalized concentrations  predicted for each
 meteorological condition  are generally (in  25 of 33
 meteorological conditions analyzed or 76%)  associated  with the
 100%  load case.

      Since the modeling analysis shows that the low-load
 operation of the  CBCP's CFBs would not increase the  impact of
the CFBs  within  0.8 km, well beyond the location of  the CBCP's
peak effect on ambient  air  quality,  it is clear that the
 low-load  operation would  not effect the  estimation of  that
peak effect.   Therefore,  lowei  loads  do  not warrant  additional
analysis  as they have no  bearing on modeling results for
critical parameters.  This  analysis  supports the  request for

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                            G  -

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 PA  88-24A


deletion of the furnace load operating limitation in Condition
II.A.8.9.b.

     The results of the assessments show that the proposed
modifications to CBCP plus the new boilers at SK result in
less adverse air quality impacts than SK oririnally, and less
adverse impacts than CBCP originally.  When evaluating the air
quality impacts of the proposed SK boilers, the sulfur content
of the oil to be used was assumed to be 0.5% as a maximum and
0.3% on an annual average.  A current BACT analysis of oil to
be used by SK in the steam boilers or by USG in the CBCP
facility would result in a requirement to use distillate oil
with a 0.05% sulfur content.  The modeling analysis for S02 in
Cases 4 and 5 is therefore conservative.  Future ambient SO2
levels will be significantly less th^n predicted.

The modeling analysis supports the requested modifications
relating to deletion of conditions prescribing load
operational ranges and more frequent use of oil during the
first year of operation of the CBCP.

                 Conclusion and Recommendation

     The proposed modifications of the CBCP will reduce the
air and water quality impacts of the previously certified
facility.  The modifications relating to use of treated
wastewater from Seminole Kraft satisfies the findings of the
Siting Board that a source of cooling water be secured that
would eliminate the use of potable water from the Floridan
Aquifer.  The implementation of the zero-discharge system
would eliminate the discharge of industrial wastewater from
CBCP and will reduce SK discharges.  This benefits the
environment by reducing or eliminating the pollutants in those
waste streams from the environment.  Zero-discharge minimizes
the adverse impacts of water discharges- to. .the .maximum.extent _
possible.

     Accordingly the Department recommends that the revised
Cedar Bay Cogeneration Project with its associated facilities
be approved subject to the modified Conditions of
Certification set forth in Appendix A.
                               VIRGINIA B. WETHERELL
                               Secretary
                               14

                            Cr-20

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                  APPENDIX A

          CONDITIONS OF CERTIFICATION
(The  Conditions of Certification included in this "
  .
 included  here;   they are available on^equest" rom*
 uT'EPA      '  Ch±ef Envirormental Policy Section; FAB-4 ;

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§

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 APPENDIX H



STORMWATER

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«  ^^^^^  x

I ^fo!L ?       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
  ,t                           REGION  IV

                           345 COURTLAND STREET. N.E.
    JUL J 2 1992               ATLANTA. GEORGIA 3O36S


   CERTIFIED MAIL

   RETURN RECEIPT
   REFt  4WM-WPEB

   Mr. Paul Stinson
   Project Hanager
   AES/Cedar Bay, Inc.
   9469 Eastport Road
   P.O. Box 26329
   Jacksonville, Florida  32218-0329

   REi  Final Issuance of NPDES Permit No. FL0041173
        Cedar Bay Cogeneration Project

   Dear Mr.  Stinson:
   SlMltn«L?ile^!!at^nalKPollUtfn1: DischarSe Elimination System
   (NPDES) permit  for the  above-referenced facility.   This action
  constitutes the Environmental Protection Agency?*  final p£m£
  decision in accordance  with Title  40,  Code of Federal
  Regulations (C.F.R.) Section 124.15(a).   The permit will become
  ZSfSril" aVpe?i£i?d' Provided that  no timely request for IT
  evidentiary hearing is  received by the Agency.

  Any interested person may contest  this decision by submittino a
  timely request  for an evidentiary  hearing (hearing)  pursuant tS
  h«r-?n«CfdUre8 t* 4° C-P'R- « 124.74.  If a  regS^ft f S a
  hearing is received by the Agency,  following review,  a
  d^?^naii0? Y111 be made an(J the  regueste? advised of the
  ad;^%de?i8i0n °n the r^tt«t.'" Until  that time,  please  be
  advised that any request will render the  permit  ineffective
  pursuant to 40 C.F.R.  S 124.15(b).  For a^S sou?c" a ^ew
  discharger, a recommencing discharger, or a  facility for which

          -^


     :he«.evident}arr hearin9T request is granted, in whole or
                            H-l
                                                          PnntfO on Recvf ;-»J F-fr*r

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                               -2-
 To request an evidentiary hearing under 40 C.F.R. S 124.74, you
 must submit an original and two copies of the request to the
 Regional Hearing Clerk at the letterhead address within thirty
 (30)  days  from service of this notice.  A copy of the procedures
 and requirements for evidentiary hearing requests and appeals to
 the Administrator is enclosed.

 Por purposes  of  judicial review under the Clean Water Act, 33
 U.S.C. S 1251 
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                Protection Afoncy
                            § 124.71
 «t 1 ?• 1 '•
  •••.I  K!lV
 '
    >r 40 CPR  Ch.I  (7-1-89  Edition)
 •rvlr-v  «.ij

 I ia«M»«


  if* i-.  M-

   t » » ••:•

   I.

  I.I

 Itl.ll .......||.
on' »•<
       X.
        I—I vUonllory H*orlnCs for
    lf*A-4tswsd  NPDES Permits •*•>
    iPA-f•mlMta* tCtA Porsails

1124.71  AsfUcsMIUy.
  (a) The regulations In this subparl
govern all formal hearlnis conducted
by EPA under CWA sections 402 and
40MD. escepl  those conducted under
Subpart P. They also govern all evi-
dentiary  hearings  conducted  under
RCRA section 3001  In connection with
the termination ol a RCRA  permit.
This Includes  termination of  Interim
status  for failure to furnish Informa-
tion needed to make a'flnal decision  A
formal hearing  Is  available  to chal-
lenge any NPDES permit Issued under
1124.1ft except for  a:central  permit.
Persons affected by a general permit
may not challenge the conditions ol a
general permit as of  right In  further
agency proceedings. They may Instead
either challenge  the general permit In
court,  or  apply for; an  Individual
NPDES permit under 1122.21  as au-
thorized In 1122.21 and then request a
formal  hearing  on line Issuance or
denial  of  an Individual permit. (The
Regional Administrator also  has the
discretion to use the procedures of
Subpart  P for general permits.  See
1124.1111.
  (b)  In  certain  cases,  evidential^
hearings under this subpart may also
be held on the conditions of UIC per-
mits, or of RCRA permits which are
being Issued, modified, or revoked and
reissued, rather than terminated or
suspended. This will  occur when Hie
conditions of the UIC or RCKA permit
In question are closely linked with the
conditions of an NPDES permit as to
                                     165
§ 124.72

which an evidentiary hearing has been
granted. See | l24.14(bM2>. Any Inter-
ested person may challenge the Re-
gional   Administrator's  Initial   new
source determination by requesting an
evidentiary hearing  under this  part.
See | 122.29.
  (c) PSD permits may never  be  sub-
ject  to  an evidentiary hearing under
this  subpart. Section  l24.74tbM2Mlv»
provides only for consolidation of PSD
permits with other permits subject to
ft panel hearing under Subpart P.
MS PR !«•«. Apr. I. IN3. as amended at M
PRiaigs.Mayl.IMti

• 114.12  Ueflalllaas.
  Por the purpose of this subpart. the
following definitions are applicable:
  "Hearing Clerk" means The Hearing
Clerk. U.S. Environmental Protection
Agency. 401 M Street. SW- Washing-
ton.  DC. 20460.
  "Judicial Officer" means a perma-
nent or temporary  employee of the
Agency appointed as a Judicial Officer
by the Administrator under these reg-
ulations and subject to Uw following
conditions:
   A Judicial Officer shall be a li-
censed  attorney.  A Judicial  Officer
shall not be employed In the Office of
Enforcement or  the Office of Water
and  Waste Management, and shall not
participate In the consideration or de-
cision of any ease In which he or she
performed Investigative or prosecute-
rial  functions, or  which Is factually re-
lated to such a case.
  (b) The Administrator may delegate
any  authority to  act In an appeal of a
given case under  this subparl  to a Ju-
dicial Officer who.  In  addition,  may-
perform other duties for EPA. provid-
ed that the delegation shall not pre-
clude • Judicial Officer from referring
any  motion or case to the Administra-
tor when the Judicial Officer decides
such action would be appropriate. The
Administrator. In deciding a case, may
consult with and  assign the drafting of
preliminary findings of fact and con-
clusions and/or a preliminary  decision
to any Judicial Officer.
  -Party-  means the EPA  trial  staff
under 1124.70 and any iierson whose
request for a hearing under 1124.74 or
whose  request to be  admitted  as  a
        40 OR Ch. I (7-1-tt Edition)
                                    4
party or to Intervene under i 124.70 or
1124.117 has Itren granted.
  "Presiding Officer" for the purposes •
of this subpart means an Administra-
tive  Law  Judge  spitolnled  under &
U.S.C. 3 IDS and designated to preside
at the hearing. Under Subparl P other
persons may also M?rve as hearing old-
cers. See 1124 IIV.
  "Regional Hearing Clerk"  means an
employee of the Agency designated by
a Regional Administrator to establish
a repository for all books, records, doc-
uments, and other materials relating
to hearings under this subpart.

• 124.73  Piling sad MtbmissiMi of «UCM-
  (a) All submissions authorized or re-
quired to be  filed with the  Agency
under this subparl shall be tiled with
the  Regional  Hearing  Clerk,  unless
olherwise provided by regulation. Sub-
missions shall be  considered filed 011
Ihe dale on winch they are mailed or
delivered  In person  to the Regional
Hearing Clerk.
  
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     of literature or other material In a for-
     eign'language shall be accompanied by
     copies of (he original publication.
       (3) Where relevant data or Informa-
     tion la contained In a document alto
     containing  Irrelevant  matter,  either
     the Irrelevant  matter shall be deleted
     or the relevant portions shall be Indi-
     cated.
      (41 Failure to comply with  the  re-
     quirements of this section or any
     other requirement In this subpart may
     result In the noncomplylng portions or
     the  submission being excluded from
     consideration. II the Regional Admin-
     istrator''or  the Presiding Of fleer.'on
     motion by any  party or *ua •ponfc. de-
     termines that  a submission falls  to
     meet'any requirement of this Subpart.
     the Regional Administrator or Presid-
     ing Officer shall direct the Regional
     Hearing  Clerk  to return the submis-
    sion, together with a reference to the
    applicable regulations. A party whose
    materials have  been rejected has  14
    Xdaya to correct the  errors and resub-
    mil.  unless  the Regional Administra-
    tor or the Presiding Officer finds good
  I cause to allow a longer time.
  __   ily If:
  (I)  Processing of the RCRA or UIC
 permit al Issue  was  consolidated with
 Ihe processing of lira'NPDES permll
 as provided In 1124.4; .
  (II) The standards for granting  a
 hearing on  the NPDES permit  are
 met;
  (III) The resolution of Ihe  NPUKS
 permll Issues Is likely lo make neces
 aary  or  appropriate  modification of
 the RCRA or UIC permll; and
  (Iv) If a PSD permit Is Involved,  a
 permittee who Is eligible for an eviden-
 tiary  hearing under Subparl E on his
or her  NPDES  permll  requests  thai
the   formal  hearing ' be  conducted
under Ihe procedures of Subparl F
and the Regional Administrator finds
that consolidation Is unllkly lo drlsy
final permll Issuance beyond Ihe PSD
one-year statutory deadline.
                                      167
   ( 134.75

    (c) These requests shall also contain:
    (1) The name, mailing  address, and
   telephone  number  of  Ihe  person
   making such request;
    (2) A clear and concise (actual state-
   ment of the nature and scope of the
   Interest of the requester;
    (3) The names and addresses of all
   persons  whom  the requester repre-
  sents; and
    (4) A statement by  Ihe requester
  that, upon  motion of any  party grant-
  ed by the  Presiding Officer, or upon
  order of the  Presiding  Officer  tua
  spontc without cost or expense lo any
  olher party, the requester shall make
  available to appear and testify, the f ol-
  lowing:
    (I) The requester;
    (II) All persons represented by the
  requester: and
    (III) All officers, directors, employ-
  ees, consultants,  and agents of the re-
  quester and the persons  represented
  by the requester.
   (»  Specific references to the con-
  tested permll  conditions,  as well as
  suggested revised or alternative permit
  conditions (Including permll denials)
  which. In the Judgment of the request-
  er, would be  required lo Implement
  the purposes and policies of the CWA.
   (6)  In Ihe case of challenges lo Ihe
 application  of  control or  treatment
 technologies Identified In the  state-
 ment  of basis or fact sheel. Identifica-
 tion of the basis for the objection, and
 the alternative  technologies or combi-
 nation of technologies which the re-
 quester believes are necessary to meet
 the requirements of the CWA.
   <1> Identification of Ihe permll obli-
 gations thai  are contested or are Inse-
 verable from contested conditions and
 should be stayed If the  request  Is
 granted by reference to Ihe particular
 contested conditions  warranting Ute
 slay.
  (•) Hearing requests also may ask
 that a formal hearing be held under
 Ihe procedures ael forth In Subpart P.
 An applicant may make such a request
 even If the proceeding does  not const I
 lute "Initial  licensing" as defined In
 1124.111.
  (d) If  the  Regional  Administrator
granU  an evidentiary hearing request.
In whole or In part. Ihe Regional Ad-
ministrator shall Identify the permit
           40 0» Ch. I (/-!-«• Edition)

  conditions which have been contested
  by  the requester and for  which Ihe
  evidentiary hearing has been granted
  Permll conditions which are not con
  tested or  for which the Regional Ad-
  mlnlslralor has denied Ihe hearing re-
  quest shall not be affected by. or con-
  sldered at.  Ihe evidentiary  hearing
  The  Regional  Administrator shall
  specify these conditions In writing In
  accordance with | I24.«0lc).
    (el   The  Regional  Administrator
  must grant or deny all requests for an
  evidentiary  hearing on  a  particular
  permit. All requests that are granted
  for  a  particular permit shall be coin.
  blned In a single evidentiary hearing.
   (f)  The  Regional  Administrator
  (upon notice to all persons who have
  already submitted hearing  request*!
  may extend the time allowed for sub-
  milling hearing requests under this
  section for good cause.

  I I24.1S Heebie* on r«|ucil for a hearing.
   (aMI) Within 30 days following the
  expiration of  the lime  allowed  by
  I 124.14 for submitting an evidentiary
  hearing request, the Regional Admin-
  istrator shall decide  the  eilenl  to
  which.  If  al all.  the request shall be
  granted, provided  thai Ihe  request
 conforms   lo  Ihe  requirements  of
  1124.14. and sets forth material Issues
 of fact relevant to the  Issuance of Hie
 permll.
  '(2) When  an  NPDES  permll for
 which  a  hearing requesl has  been
 granted constitutes "Initial licensing"
 under I 124.111. the Regional Adminis-
 trator may elect to hold a formal hear
 Ing under the procedures of Subparl P
 rather  than under the procedures ol
 this subpart even If no person has re-
 quested lhal Subparl P be applied. If  '
 Ihe  Regional  Administrator  makes
 such a.declslon. he or she shall Issue a
 notice of hearing under | 124.116. All
 subsequent proceedings shall then  be
 governed   by   II124 111    through
 124.121. eicepl thai any reference to a
 drafl permit shall mean  the  final
 permit.
  (3) Whenever the Regional  Admlnls
 tralor grants  a request made unUrr
 I l24.14(cMt)  for  a  formal   hearing'
under Subpart P on an NPDES pi-unit
that does not constitute an maul  H
                                                                                   168

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   «•"••  ""«>' I IM.I1I. the  Regional
   Administrator ahall lasue a notice of
   hearing  under 1124.1 Ig  Including a
   statement, that the permit  will be
   processed  under the  procedures of
   Bubpart F unless a written objection to
   received within 30 days. If no valid ob-
   Jectlon  to  received, the  application

   II 134.117  through  124.l3l!>Mexcept
   that any reference  to  a draft permit
   ahall mean the final permit. If-a valid
   objection to received, this aubpart ahall
   be applied Instead.
    (b) If a  request  for a  hearing to
   denied In whole or In part. Ihe Region-
   al Administrator shall brleny state the
   reasons. That denial  la  subject  lo
'  review  by  the  Administrator under
   I lM.tlv                      ^^

   111474  OMIgaUoa  to aaftmll  „!•„*.
                    •fare a ftaal fsnatt to
\n
    In any case where the Regional Ad-
  ministrator  elected to apply  the  re-
  qulremenu of 1124.!4  "Interested  person outside the
  Agency"  Includes  the permit appli-
  cant,  any  person  who  filed  written
  comments  in  the  proceeding,  any
  person who requested Ihe hearing, any
  person who requested to participate or
  Intervene In the hearing, any  partici-
  pant In the hearing and any other In-
  terested  person not employed  by the
  Agency at the time of the communica-
  tions,  and  any attorney of record for
  those persons.
   CbMll No Interested person outside
  the Agency or member of the Agency
  trial staff  shall make or  knowingly
  cause to be made  to any members of
  Ihe declslonal body, an ex  part* com-
  munlcatlon  on the merits of ihe pro-
  ceedings.
   (2)  No member of  the  decisions!
  body shall make or knowingly cause to
  be made to any Interested person out-
 side  ihe  Agency or member of Ihe
 Agency trial staff, an ex parfe commu-
 nication on the merits of the proceed-
 ings.
   (3) A member of  the declslonal body
 who  receives or who makes or  who
 knowingly causes to be made a com-
 munication prohibited by this subsec-
 tion shall file with  the Regional Hear-
 Ing Clerk all written communications
 or memoranda staling Ihe  substance
 of all oral  communications together
 with all written responses and memo-.
 randa slating the subslance  of all oral
 responses.
  (c) Whenever any member of ihe de-
 clslonmaklng body receives an ex parle
 communication  knowingly  made  or
 knowingly caused to be  made  by a
 party or representative of a parly In
 violation of  this section, the person
 presiding at the stage  of the  hearing
 then In progress may.  to the extent
consistent with Justice  and the pulley
of the CWA. require the parly to show
cause why Its claim or  Interest In  the
proceedings  should  not be dismissed.
denied,  disregarded, or otherwise  ad-
                                                                                                                                     «0 CM 0. I (7-I-0 |dlt|.n)

                                                                                                                                             n *ccounl 0|
                                                                                                                              id) The prohibitions of this section'
                                                                                                                            begin to apply  upon Issuance of  the
                                                                                                                                     lh* "r'nl 0| • "earing under
                                                                                                                                    or 1 124.114. This prohibition
             - *pr  •
  «t MM3. Sept. M. IH4I

  Il24.7t

    la) Any person may submit a request
  to be admitted as a parly within  IS
  days afler Ihe dale of mailing, publics
  lion, or posting of notice of the grant
  of an evidentiary hearing, whichever
  occurs  last. The  Presiding  Officer
  shall grant  requests  Dial meet the re-
  qulremenu of || 124.14 and 124.76
   (b) Afler Ihe expiration of Ihe time
  prescribed In paragraph (a) of this sec-
  tion any person may rile a motion for
  leave lo Intervene  as a  parly. This
  motion must meet the requirements ol
  II 124.74 and 124.16 and set forth the
  grounds for  the proposed Intervention
  No  factual   or  legal  Issues,  besides
  those  raised by  timely  hearing  re
  quesU.  may  be proposed  except for
  good cause.  A motion for  leave  lo In-
  lervene must also contain a verified
 statement showing good cause for Hie
  failure lo file a limely request  lo be
 admitted as a parly. The Presiding Of-
 flqer shall grant the motion only upon
 an express finding on the record thai:
   ( I ) Extraordinary circumstances jus-
 tify granting the motion:
   (2) The Intervener has consented lo
 be bound by:
   III Prior  written  agreements and
 stipulations by and between the exist-
 ing parties: and
   (II) All orders previously entered In
 the proceedings: and
   (3) Intervention will not cause undue
 delay or prejudke the rlghta of the ex
 toting parties.

 II24.M filing aa4 Mr*k«.
  (a) An original and one 1 1 » copy of
 all written submissions relating |o an
 evidentiary  hearing  filed  after  ihr
 notice to published shall be filed with
 the Regional Hearing Clerk.
  (b) The party filing any submission
shall also serve a copy of each subnii*.
                                                                                                                       170

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                           I Affjoncy
    •Ion  upon the  Presiding Officer and
    each party of record. Service shall be
    by mall or personal delivery.
     let Every submission shall be accom-
    panied by an acknowledgment of senr-
   ilcetbythei person served or a cerllfl-
   irate of service clllng the date, place.
   .time.) and 'manner of service and the
    names of the persons served.
     (dl The Regional  Hearing  Clerk
    •hall maintain and furnish a list con-
    taining the name, service address, and
    telephone number  of all parties and
    their attorneys or duly authorised rep-
    resentatives  to  any  person upon  re-
   quest.

  , III4JI  Assl|a«»twl   of  Atawlstrallve
       Law Jwsge.
     No later than  the date  of mailing.
    publication, or posting of the notice of
   • 'grant  of  an  evidentiary  hearing.
   whichever occurs last,  the Regional
   Administrator shall refer the proceed-
   ing to the Chief Administrative Law
_>_ Judge who shall assign an Admlnlstra-
J- tlve Law  Judge to  serve as Presiding
 I  Of(|cer for the hearing.

G^ilM'Jl  Csassllisllss) and severance.
     (a) The Administrator. Regional Ad-
   ministrator, or Presiding Officer, has
   the discretion to consolidate. In whole
   or In part, two or more proceedings to
   be held under this  subpart. whenever
   It appears that a Joint hearing on any
   or all of the matters In Issue would ex-
   pedite or simplify consideration of the
   Issues and that no party would be prej-
   udiced thereby.  Consolidation  shall
   not affect the right of any party to
   raise  Issues  that might  have  been
   raised had there been  no consolida-
   tion.
       If  the  Presiding  Officer  deter-
   mine* consolidation Is  not conducive
   to an expeditious, full, and fair hear-
   ing, any party or Issues may be severed
   and heard In a separate proceeding.
   • IS4JI  Prebtsttag CMNCMWI**.
      The   Presiding   Officer.  tu«
   ••ONfe. or at the request of any party.
   may direct the parties  or their attor-
   neys or  duly authorised representa-
   tives to appear at a specified time and
   place for one  or more conferences
   before or  during  a hearing,  or to
   submit  written proposals or  corre-
                            8
 •pond for the purpose of considering
 any of the matters set forth In 'para-
 graph  of this section.
  (b) The Presiding Officer shall sllow
 a ressonsble period before the hearing
 begins for the orderly completion of
 all prehearlng procedures and for the
 submission and disposition of all pre-
 hesrlng motions.  Where the circum-
 stances warrant, the Presiding Officer
 may  call a prehearlng conference to
 Inquire Into the use of available proce-
 dures contemplated by the parties and
 the time required for their completion.
 to establish a schedule for their  com-
 pletion. and to set a tentative dale for
 beginning the hearing.
   Scheduling as many of the fol-
 lowing as are deemed necessary and
 proper by the Presiding Officer:
  (II  Submission of  narrative state-
 ment* of position on each factual  Issue
 In controversy:     :
  (II) Submission of written testimony
 and documentary  evidence (e.g..  affi-
 davits. data, studies, reports, and any
 other type of written material) In sup-
 port of those statements; or
  (III) Requests by any party for the
 production of additional documenta-
 tion. data, or other Information  rele-
 vant and material to the I acU In Issue.
                                       171
|»4.M

  (g) Grouping participants with sub-
stantially similar Interests to eliminate
redundant  evidence, motions, and ob-
jections.
  (1) Such  other matters that may ex-
pedlle the  hearing or aid In the dispo-
sition of the matter.
  (d) At a prehearlng conference or at
some other reasonable lime set by the
Presiding  Officer,  each  parly  shall
make available lo all oilier parlies lite
names  of  the expert  and oilier wit-
nesses It eipecls lo call. Al II* discre-
tion or at the request of Ihe Presiding
Officer, a  parly may  Include a brief
narrative summary  of any witness's
anticipated testimony. Copies of any
written  testimony, documents, papers.
exhibits, or materials which a  party
eipecls to Introduce Into evidence, and
the admlnlslrallve record required by
1124.1* shall be marked for Identifica-
tion as ordered by the Presiding Offi-
cer. Witnesses, proposed written lesll-
mony.   and oilier  evidence  may be
added or amended upon order of the
Presiding  Officer   for  good   cause
shown. Agency employees and consult-
ants shall  be made available as wit-
nesses  by  the Agency lo the  same
extent  that  production of such wit-
nesses   Is  required  of olher parlies
under    I  !24.74(cM4).   (See   also
I l24J5(bMie).)
  (e) The Presiding Officer shall pre-
pare a wrlllen prehearlng order recit-
ing the  actions taken al each prehear-
lng conference and  selling forth Ihe
schedule for the hearing, unless  a
transcript  ha* been taken and accu-
rately   reflects  these  mailers.  The
order shall Include a wrlllen  slate-
menl of the areas  of tactual agree-
ment and  disagreement  and of. Ihe-
melhods and procedures to be used In
developing  the evidence and the re-
spective duties of the partlss In con-
nection therewllh. This order shall
control  the subsequent course of Ihe
hearing unless modified by Ihe Presid-
ing Officer for good cause shown.

IIS4J4  muMMry delenataalloa.
  (a) Any party to an evidentiary hear-
ing may move wllh  or without sup-
porting  affidavit* and briefs lor a sum-
mary determination In It*  favor upon
any of the  Issues being adjudicated on
the basis that there Is nu genuine Issue
         40 CM Ch. I (7-1-tt idllUn)

of  material  fact  for  determination.
This motion shall be filed at least 45
days before the dale sel for the hear-
ing, except  that upon  good  cause
shown the motion may be filed al any
time before Ihe close of Ihe hearing.
  (b) Any olher parly may.  within 30
days after service of Ihe motion. Ille
and servr a response lo It or a counter-
molloii for summary  determination.
When  a motion for summary determi-
nation to made and supported, a parly
opposing  Ihe  motion  may  nol resl
upon mere allegallons or denials but
must show, by affldavll or by olher
materials subject  to consideration by
the Presiding Officer, thai there Is  a
genuine Issue of material (act  tor de-
termination al the hearing.
  (c) Affidavits shsll be made on per-
sonal knowledge,  shsll sel forth facts
that would be admissible In evidence.
and shall show affirmatively that the
affiant Is competent lo testify  to the
matters staled therein.
  (d) The Presiding Officer may  sel
Ihe matter for oral argument snd call
for the submission of  proposed find-
ings, conclusions, briefs, or memoran-
da of law. The Presiding  Officer shall
rule on the motion nol more than 30
days after the dale  responses  lo the
motion are filed under paragraph (b)
of this section.
  (e) If all factual Issues are decided
by summary  determination,  no hear-
ing will be held and the Itetldlng Offi-
cer shall  prepare an Initial decision
under  1124.8*. If summary determina-
tion to denied or  If partial summary
determination to  granted, the  Presid-
ing Officer shsll Issue a memorandum
opinion  and  order. Interlocutory  In
character, and the  hearing  will pro-
ceed on Ihe remaining Issues. Appesls
from  Interlocutory  rulings  are gov-
erned by 1124.00.
  (f) Should II appear from Ihe affida-
vits of  a  parly opposing  a motion lor
summary determination that lie or she
cannot for reasons stated present, by
affldavll or otherwise. IscU essenllsl
to  Justify his or  her opposition.  Hie
Presiding  Officer  may  deny  (lie
motion or order a continuance lo allow'
additional affidavit*  or other Informs
lion to be obtained or may make such
olher order as to Jusl and proper.
                                                                                                                         172

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                             Agency
      IIS4.U Hearts* procedure.
       (aMl) The permit applicant always
      bean  the  burden of persuading  the
      Agency that a permit authorizing pol
      lutanU to  be  discharged should  be
      uwued and  not denied.  ThU burden
     does not shift.
       NOTK- In manr eases the doeumcnU con-
     tained In UM administrative record, to par-
     ticular the fact sheet or •(•icment of bsaki
     and th* response to comments. abeuM ads-
     •juaUly discharge Uus burden.
       (3) The  Agency has the burden  of
     going forward to present an affirma-
     tive case In support of any challenged
     condition of a final permit.
,      (3) Any hearing participant who. by
     raising material Issues  of fact, con-
     lends:
       III That  particular conditions or re-
     qulremenu In the permit are Improper
     or Invalid, and who desires either
       (At The Inclusion of new or different
     conditions or requirements; or
        The deletion of those conditions
 XI oc requirements; or
       III) That the denial or Issuance of a
  |  permit  Is otherwise  Improper  or  In-
     valid. shall  have the burden of going
   1 forward to present an affirmative case
 ~~-J at the conclusion >:'  ••?">  Agency case
     on the challenged requirement.
      (b) The Presiding Officer shall con-
    duct a fair and Impartial hearing, take
    action to avoid  unnecessary delay In
    the disposition of the proceedings, and
    maintain order.  For these purposes.
    the Presiding Officer may:
      (I) Arrange and Issue notice of the
    date. time, and place of  hearings and
    conferences;
      <» Establish the methods and proce-
    dures to be used In the development of
    the evidence;
      (I)  Prepare, alter  considering the
    views  of the  participant*,  written
    statements  of  areas  of  factual dis-
    agreement among the participants;
      (4) Hold conferences to settle, sim-
    plify. determine, or strike any  of the
    Issues In a  hearing, or  to  consider
    other maltera that may facilitate the
    expeditious disposition of the hearing;
      (ft) Administer oaths and  affirma-
    tions;
      (•I Regulate the course of the hear-
    ing and govern the conduct of partici-
    pants:
      ill Eiamlne witnesses;
                             § 134.15

   (SI Identify and refer Issues for In-
 terlocutory decision under 11344*0;
   (91 Rule on. admit, exclude, or limit
 evidence:
   (10) EslablUh the time for filing mo-
 tions, testimony, and other  written
 evidence, briefs,  findings,  and other
 submissions;
   (ll» Rule on motions and other pro-
 cedural  matters pending before him.
 Including but not limited to motions
 for summary determination In accord-
 ance with | 124.94;
   (I2> Order that the hearing be con-
 ducted In stages whenever the number
 of parlies to Urge or the Issues are nu-
 merous and complex:
   (19) Take any action not Inconsist-
 ent with the provisions of this subparl
 for Ihe  maintenance of order at the
 hearing  and for the expeditious, fair.
 and Impartial conduct of the proceed-
 ing;
   (14) Provide for Ihe testimony of op-
 posing witnesses lo  be heard simulta-
 neously  or for such  witnesses to meet
 outside Ihe hearing lo resolve or Iso-
 late Issues or conllkts;
   (IS) Order thai  trade secrets  be
 Ireated as confidential business Inlor
 msllon  In  accordance with  || 132.1
 (NPDESI and 270.I2URCRA) and 40
 CPR Part 2; and
   (1C) Allow such cross-examination as
 may be required for a'full and Irue dis-
 closure of Ihe facts.  No cross-examina-
 tion shall be allowed on questions of
 policy except to the extent required to
 disclose the factual basis for permit re-
 quirements, or on questions of law. or
 regarding matters (such as (lie validity
 of effluent limitations guidelines) thsl
 are not subject to challenge In an evi-
 dentiary hearing. No Agency witnesses
 shall be required to testify or be made
 available  for cross examination  on
 such maltera. In deciding whether or
 not lo  allow cross-examination,  the
 Presiding Officer shall consider  (he
 likelihood of clarifying or resolving a
disputed  Issue of  material  fact com-
pared lo  olher available methods. The
party seeking cross-examination has
the burden of demonstrating that this
standard has been mel.
  (c) All  direct and  rebuttal evidence
at an evidentiary hearing shall be sub-
milled In written form, unless, upon
motion and  good cause  shown. Hie
                                       173
 § I24.M

 Presiding Officer determines that oral
 presentation of  the  evidence on any
 particular fact will materially asslsl In
 Ihe efficient Identification and clarifi-
 cation of Ihe Issues. Written testimony
 shall be prepared In narrative form.
   (dNI) The  Presiding  Officer  shall
 admll all relevant, competent, and ma-
 terial evidence, except evidence thai Is
 unduly  repetitious. Evidence may be
 received at any  hearing even though
 Inadmissible under the  rules  of evi-
 dence applicable lo  Judicial proceed-
 ings. The welghl lo be given evidence
 shall be determined  by  Its reliability
 and probative value.
   (2) The  administrative record  re-
 quired  by  | I24.lt shall  be  admitted
 and received In evidence. Upon motion
 by any party  the Presiding Officer
 may direct that a witness be provided
 to sponsor a portion or portions of Ihe
 administrative  record. The  Presiding
 Officer, upon finding that the stand-
 ards In  | !24.U(bM3) have been mel.
 shall direct the  appropriate parly lo
 produce Ihe witness for cross-examliia-
 lion. If a sponsoring witness cannot be
 provided, the Presiding  Officer may
 reduce the welghl accorded the appro-
 priate portion of  Ihe record.
  Non: Recelvlni (he administrative record
 Into evidence automatically serves aeveral
 purpose*: (11 II document* the prior couise
 •f the proceedlnss: i2Hl provides a record
 of Ihe views of affected  persons  lor consld-
 eiatton by the asency declslonmafeer: and
 11) It provides factual material for use by
 (he declslofunaker.
  (3) Whenever any evidence or tesll-
 mony la excluded by Ihe  Presiding Of-
 ficer as Inadmissible, all such evidence
 or testimony existing In  written form
 shall remain a part of Ihe record as an
 offer of proof. The parly seeking Ihe
 admission of oral lesllmony may make
 an offer of proof, by  means of a brief
 statement on the record describing the
 testimony excluded.
  (4) When two or more parlies have
aubslanllally similar Interests and po-
sitions,   the  Presiding Officer  may
 limit the number of attorneys or olher
 party representatives  who will be per-
 mitted lo cross-examine  and lo make
and argue motions and objections on
 behalf  of  lliose parlies. Attorneys
may. however, engage In cross-exainl-
nation relevant  lo mailers  not  ade-
         40 CM Ch. I (7.1-M Edition)

 quately covered by previous cross-ex-
 amination.
  (St Rulings of the Presiding Officer
 on the admtsslbilliy of evidence or les
 llmony. Ihe  propriety of cross-exami-
 nation, and other procedural matters
 shall appear In thr record and  shall
 control lui liter proceedings, unless re-
 versed as a result of an Interlocutory
 appeal taken under 1124.90.
  (6)  All objections shall  be  made
 promptly or be deemed waived. Parlies
 shall be presumed lo have laken ex-
 ception lo an adverse ruling.  No objec-
 tion shall be deemed waived by  fur-
 ther participation In the hearing.
  (e) Admttiton of evidence on  eitvl-
 ronmenfaf impact*  If a  hearing  Is
 granted under this subpart for a new
 source subject to NEPA. the  Presiding
 Officer may  admit evidence  relevant
 lo any environmental Impacts of the
 permuted  facility   If  Ihe  evidence
 would be relevant lo the Agency's obli-
 gation  under  | I22.29(CM3>. If  the
 source  holds   a  final   KPA-Usuetl
 RCRA. PSD. or UIC permit, or an
 ocean dumping  permit   under  Hie
 Marine  Protection.  Research,   and
 Sanctuaries  Act  (MPRSA).  no  such
 evidence shsll be admitted  nor  shall
 cross-examination be allowed relating
 lo:
  (I) Effects  on  air quality. (3) effects
 attributable lit underground injection
 or hazardous waste management prac-
 tices, or (3) effects of ocean dumping
 subject lo Ihe  MPRSA.  which  were
 considered or could have been consul
 ered  In  Ihe PSD.  RCRA.   UIC. or
 MPRSA permll  Issuance proceedings.
 However.  Ihe presiding officer  may
 admll  without  cross-examination or
 any supporting  witness relevant  por- ,
 lions  of  the revord of PSD. RCRA.
 UIC. or MPRSA permll Issuance  pro-
 ceedings.

 MS FH MM4. Apr  I. !»•). as amended at «S
 PR IMS]. Sept. as. IM4I

 II24.M  Motion*.
  (at Any party may file a  motion iin-
cluding a motion to dismiss a particu-
 lar  claim  on  a contested  Issue i  with
 the Presiding Officer on  any ntallrr
 relating lo Ihe proceeding. All motion*
shall be In writing and served as i»io
vlded In 1124.10 except lliose made un
                                                                                174

-------
                  •rotocHon
    the  record durlni  an  oral  hearing
    before the Presiding Officer.
      Ib) Within 10 days after service of
    any  written motion, any part to the
    proceeding may file a response lo the
    motion. The time for response may be
    shortened lo 3 day* or extended for an
    additional  10  days by  the Presiding
    Officer for food cauae ahown.
      Id  Notwithstanding   | in A.  any
    party may file with the Presiding Offi-
    cer a motion seeking to apply to the
    permit  any regulatory  or statutory
    provision  Issued or  made available
    after the Issuance of the permit under
    1124.11. The  Presiding  Officer shall
    grant any motion to apply a new statu-
    tory provision unless he or she finds It
   ^contrary to legislative Intent. The Pre-
    siding Officer  may grant a motion lo
    apply a new regulatory requirement
    when appropriate to carry out the pur-
    pose  of CWA. and when no patty
    would b* unduly prejudiced thereby.

XflSitT stecstdaflMartegs.
 \    la) All orders Issued by the Presiding
 Q  Officer, transcripts of oral hearings or
    arguments, written statements of posi-
    tion, written direct and  rebuttal testi-
    mony, and any other data, studies, re-
    ports, documentation. Information and
    other  written  material  of any kind
    submitted In the proceeding shall be a
    part of the hearing record and shall be
    available to the public except as pro-
    vided In || 122.7  and 370.12
    IRCRA). In the Office of the Regional
    Hearing Clerk, as soon as It It received
    In that office.
      Evidentiary hearings shall  be
    either stenographlcally  reported ver-
    batim or tape recorded, and thereupon
    transcribed. After the hearing, the re-
    porter shall certify and  file with  the
   Regional Hearing Clerk:
    (I) The original  of  the transcript.
   and
    (2) The exhibits received or offered
   Into evidence at the hearing.
    10 The Regional Hearing Clerk shall
   promptly notify each of the parties of
   the filing of the certified transcript of
   proceedings. Any party who desires a
   copy of the transcript of the  hearing
   may obtain a copy of the  hearing tran-
   script  from  the  Regional  Hearing
   Clerk upon payment of costs.
                             I I24.M

   Id) The Presiding Officer shall allow
 witnesses, parties, and their counsel an
 opportunity to submit such  written
 proposed corrections of the transcript
 of any  oral testimony taken al the
 hearing, pointing  out errors that may
 have  been  made  In  transcribing the
 testimony, as are required lo make the
 transcript conform to  the testimony.
 Except In unusual cases, no more than
 M days shall be allowed for submitting
 such corrections from Ihe day a com-
 plete  transcript of  the  hearing be-
      i available.
fMSlags  of fscl  aad
 • I24.U
                 ef.
   Within 46 days after the certified
 transcript to filed, any party may file
 with the Regional Hearing Clerk pro-
 posed findings of fact and conclusions
 of tew and a brief In support thereof.
 Briefs shall contain appropriate refer-
 ences to the record.  A copy of these
 findings, conclusions, and brief shall
 be served upon all the  other  parties
 and the Presiding Officer. The  Presid-
 ing Officer, for good cause shown, msy
 extend the tune for filing  the pro-
 posed findings and conclusions  and/or
 the brief. The Presiding Officer may
 allow reply briefs.  *

 • HIM DecWem.
  la)  The  Presiding Officer  shall
 review and evaluate the record.  Includ-
 ing the proposed findings and conclu-
 sions. any briefs filed by the parties.
 and any Interlocutory decisions under
 I I34.M) and shall Issue and file his Ini-
 tial decision with l|ie Regional Hear-
 ing Clerk. The Regional Hearing Clerk
shall Immediately serve copies  of the
 Initial decision  upon all parties (or
their counsel of record)  and the Ad-
ministrator.       '
  Ib) The Initial decision of the Presid-
ing Officer shall automatically become
the  final decision 30  days after IU
service unless within thai lime:
  IDA party files a petition for  review
by  the  Administrator  pursuant  to
I I24.tl: or
  111  The  Admlnlslrslor  sua jponir
files a notice lhal he or she will review
Hie decision pursuant Co | 124.01.
                                      175
 1134.90

 • II4.M  NUrl«c«l»rr s»s«al.
  la) Except  as  provided  In this sec-
 lion, appeals lo the Admliilslralor may
 be taken only under 1124.01. Appeals
 from orders or rulings may be taken
 under this section only  If the Presid-
 ing Officer,  upon motion of  a party.
 certifies those orders or  rulings to tlie
 Administrator  for  appeal  on  the
 record. Requests lo the Presiding Offi-
 cer for certification  musl be filed In
 writing  within 10  days  of service of
 notice of Ihe order, ruling, or decision
 and shall slate  briefly the  grounds
 relied on.
  Ib) The Presiding Officer may certi-
 fy an order or ruling  for appeal lo the
 Administrator If:
  II) The order or ruling Involves an
 Important question on which Ihere b
 •ubslanllal  ground for  difference of
 opinion, and
  12) Either: II) An Immediate appeal
 of the order or ruling will materially
 advance Ihe  ultimate completion of
 the proceeding; or
  ill) A review after the final order Is
 Issued will be Inadequate or Ineffec-
 tive.
  IO If the Administrator decides that
 certification  was Improperly granted.
 he  or  she shall  decline  lo hear Ihe
 appeal.   The   Administrator  shall
 accept or decline all Interlocutory ap-
 peals within 30 days of  their submis-
 sion: If  the Administrator lakes  no
 action within  thai lime,  the appeal
 shall  be  automatically   dismissed.
 When  Ihe Presiding  Officer  declines
 to certify an order or  ruling lo Ihe Ad-
 mlnlslralor   for   an   Interlocutory
 appeal. It may be reviewed by the Ad-
 ministrator only upon appeal from the
 Initial  decision of the Presiding Offi-
cer, except  when the Administrator
determines,  upon motion  of a  party
and In exceptional circumstances, lhal
to delay review would nol be In  the
public  Interest. Such  motion shall  be
made within ft days after  receipt of no-
llflcatlon lhal the Presiding Officer
has  refused  lo certify  an order  or
ruling  for Interlocutory appeal to the
Admlnlslrator.  Ordinarily, the  Inter-
locutory appeal will be decided on the
basis of the submissions made to the
Presiding Officer. The Administrator
may. however, allow briefs and oral ar-
gument.
          40 Cf * CK. I (7-1-49 Edit!**)

   (di In exceptional circumstances, the
 Presiding Officer may stay the  pro-
 ceeding pending a decision by the Ad-
 ministrator upon an order  or  ruling
 certified by the Presiding Officer for
 an Interlocutory appeal,  or  upon the
 denial of such certification by the Pre-
 siding Officer.
   
-------
      review,  the Administrator aha! I IMUC
      an order  either granting or denying
      the petition for review. When the Ad-
      ministrator grants  •  petition  for
      review or determines under paragraph
        Upon granting  *  petition  for
      review,  the Regional  Hearing Cbrk
      •hall promptly  forward a copy of the
      record to  the  Judicial  Officer and
      •hall retain a complete duplicate copy
      of the record In  the Regional Office.
       1d> Notwithstanding  the grant of a
      petition  for review or a determination
'  '  under paragraph  of this aecUon to
   ""review a decision,  the Administrator
   '•  nay summarily affirm without opin-
      ion and Initial decision or the denial of
 _i-  a requeat for an  evidentiary hearing.
 ->—   (e)  A petition to the Administrator
      under paragraph (a) of this section for
      review of any Initial decision or the
     denial of an  evidentiary hearing  Is.
     under •  U.S.C.  704. a prerequisite to
     the Keeking of Judicial review of the
     final decision of  the Agency.
        If a party  timely file* a petition
     for review or If the Administrator •••
     •ponte orders review, then, for pur-
     poses of judicial review, final Agency
    .action on an Issue occurs as follows:
       (I)   If  the  Administrator  denies
     review or summarily affirms without
     opinion  as provided  In  | I34.*l(d>.
     then the Initial  decision or denial be-
     cornea the  final Agency  action and
     occurs upon the service  of notice  of
     the Administrator's action.
       <» If the Administrator Issues a de-
     cision without remanding  the proceed-
     ing then  the final permit, redrafted as
     required  by the  Administrator's origi-
     nal decision,  shall  be reissued and
     served upon all parties to the appeal.
       <3l If the Administrator Issues a de-
     cision remanding the proceeding, then
     final Agency action oecun upon com-
     pletion of  the remanded proceeding.
     Including any appeals to the Adminis-
     trator from the results of  the remand-
     ed proceeding.
       <•> The petitioner may file a brief In
     support of the petition within 21 days
     after the Administrator has granted a
     petition for review.  Any  other party
     may file  a responsive brief within  31
                           9124.111

days  of service of  the  petitioner's
brief. The  petitioner then may file a
reply brief  within 14 days of service of
the responsive brief. Any person may
file an smtciu 6rte/ for the consider-
ation of the Administrator within the
same time  periods  that govern reply
briefs. If  the  Administrator deter-
mines. »um  iponte. to review an Initial
Regional Administrator's decision or
the denial of a request for an eviden-
tiary hearing, the Administrator shsll
notify the parties of the schedule for
filing briefs.
  (h)  Review by the Administrator of
an Initial decision or the denial of an
evidentiary hearing shall be limited to
the Issues specified under paragraph
(a) of this section, except that after
notice to all parties, the Administrator
may raise  and decide other  matters
which he or she considers material on
the basis of the record.
                                        177

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•ll
.(.  .
•I
 I .
      I  J.
    .I,.
4  j«JH|  ,». .»

 t  Iliuqi    Hi.

   I?! I
    I
          o

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                                        PERMIT NO.  FL0041173
                                        Minor Non-POTW

          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            REGION IV
              AUTHORIZATION TO DISCHARGE UNDER THE
         NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
    ./           the Provisi°ns  of  the Clean Water Act, as
  amended (33  U.S.C.  1251 et  seq.; the  "Act"),

         AES Cedar Bay,  Inc.
         1001  North 19th Street
         Suite 2000
         Arlington, VA   22209

  is authorized to discharge from a  facility located at

         Cedar Bay Cogeneration Project
         9469  Eastport Road
         Duval  County
         Jacksonville, Florida  32218
 to receiving waters named

        St. Johns and Broward Rivers


 in accordance with effluent limitations,  monitoring
 requirements, and other conditions set forth herei?.   The
 permit consists of this cover sheet,  Part I  6 pages  Part IT
 11 pages,  Part III 1 pages  and Attachment A.     ^  '


        This permit shall become effective on October  1,  1992.
                                         to
   July 22, 1992
Date Issued
                         W. Ray Cunningham, Director
                         Water Management Division

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                                            PART I

A.  EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL

1.
                                                                     Page 1-1
                                                                     Permit No. FL0041173
                                      st> JohM Rlver via the                        '
2.  The PH shall not be less than 6.5 standard units nor greater than 8.5 standard units. V
3-  ss? as a rvsffira^.sn-'-'0- ta other than
it  Serial number assigned for identification and nonitoring purposes; the discharge is intermittent.

                              ^^^                                                 sh.U ta

-------
                                                PART I
                                                                                Page 1-2
                                                                                Permit Ho. PL0041173
 B.
      EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
                                 ^                                    -Va°dtin9 *s~* the

     Such discharges shall be limited and monitored by the permittee as specified below,
 PARAMETER
                                   DISCHARGE LIMITATIpMS
                                   Instantaneous "   -
                                       Report
                                       50 2/
                                       Report
                                       Report
                                       Report
                                       Report
                                       Report
                                       Report
                                       Report
                                       Report
                                       Report
                                       Report
                                       Report
                                       Report
                                       See item 7,
                                                          MONITORING REQUTRRMRMTg
                                                          Measurement: 	
 Flow,  MGD
 Total  Suspended Solids, mg/1
 Total  Recoverable Copper, mg/1 3_/
 Total  Recoverable Zinc, mg/1  3_/
 Total  Recoverable Mercury, mo/1 3/
 Total  Recoverable Arsenic, mg/1 f/
 Total  Recoverable Antimony, mg/1 3_/
 Total  Recoverable Beryllium, mg/1 3/
 Total  Recoverable Cadmium, mg/1 3/
 Total  Recoverable Lead, mg/1 3/ ~
 Total  Recoverable Nickel, mg/1 3/
 Phenol, mg/1 3_/
 Naphthalene, mg/1  3_/
 Toluene, mg/1 3_/
Additional Monitoring

 2.
3.
4.  Limitations and monitoring requirements are not applicable during periods
5.
                                                   page 1-3,
I/Week
I/Week
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
1/2 Weeks
I/day of discharge
Sample Type
Pump Logs
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
    a grab
                  for
                                                                                                °"
                                                                              of no discharge.
    year,  the permittee shall  provide
                                             CONTINUED

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                                                                         Page 1-3
                                                                         Permit No. FL0041173
                                              PART I

 B.  EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL (Continued)

 6.
 7.
                                                                           ass*
     Total Suspended Solids
     Total Recoverable Copper
     Total Recoverable Arsenic
     Total Recoverable Beryllium
     Total Recoverable Chromium
     Total Recoverable Nickel
     Naphthalene
     Biochemical Oxygen Demand (5-day)
     Dissolved Oxygen
     Phosphorus
                                        Total Recoverable Mercury
                                        Total Recoverable Zinc
                                        Total Recoverable Antimony
                                        Total Recoverable Cadmium
                                        Total Recoverable Lead
                                        Phenol
                                        Toluene
                                        Total Organic Carbon
                                        Total Kjeldahl Nitrogen
                                        Oil and Grease
iHter»Ute»£al
                                  £°r """""""on ">d »°nitorlng purpo.es, the discharge Is
2/  Applicable to any flow up to the flow reBulting from a 10-year,  24-hr storm event.


17


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                                                                            Page 1-4
                                                                            Permit No. FL0041173
                                              PART I
C.  EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
1.
                                                                              5SS&
     Such discharges shall be limited

 PARAMETER
                                   and monitored by the permittee as specified below:
Flow,
Total
Total
Total
Total
Total
Total
Total
Total
Total
MGD
Suspended Solids,  mg/1
Recoverable Copper,  3_/ mg/1
Recoverable Zinc,  mg/1 3_/
Recoverable Mercury, mg/1 3/
Recoverable ArsenS,' mg/1 I/
Recoverable Antimony, mg/1 3/
Recoverable Beryllium, mg/1 I/
Recoverable Cadmium, mg/1 I/
Recoverable Lead,  mg/1 3/
                                                        MONITOR™*
                                      50 2/
                                      Report
                                      Report
                                      Report
                                              Maximum   Measurement
                                                                                Sample Type
                                                                                     Puinp
                                                                 Weeks
                                                             T/2 I£5
                                      Report
                                      Report
                                      Report
                                      Reoort
                                                               2
                                                             \/l
                                                                                     Grab
                                                                                     Grab
                                                                    ,
Additional Monitoring

2.  The pH shall  not be less than 6.5

3.  There
    shall
                                           . 6. page M.    i//di~talg.

                                    standard units nor greater than 8.5 standard units


                                                           'ater!"
--
 I
Ji
                                           CONTINUED

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C.  EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL (continued)       *£«"*,.  FL0041173
4.  Monitoring requirements are not applicabie during periods of no discharge


''S^^^&SSS&SS&^vss.'
    r>T^OT™m tatA ^^^«» _&.	.	*• +  •
   Total RcverablCopTOr               m°5af Recoverabl« Mercury
   Total Recoverable Art^lc              1°+*} Recov*rable Zinc
   Total Recoverable Beryllium             «°5af Recoverable Antimony
   Total Recoverabll ChSiluT               *  Recovera"« CadmW
                                                     Carbon
   Phosphorus                            T?tal KJeldahl Nitrogen
                                        Oil and Grease
                                                                   ^ and suited with the
                                                                             •


                                 *« identification and .onitoring purposes; the disch«ge is
  SSSS3     tc%SdrS:^! U °nly ra"Uired wh™ • •"-*«»• occurs,  see Part ,„., for

-------
                                            Page 1-6
                                            Permit No. FL0041173
                                PART I
D.  SCHEDULE OF COMPLIANCE
1.  The permittee shall achieve compliance with the effluent
    limitations specified for discharges  in accordance with the
    following schedule:                              .

    a.   Attainment of effluent limitations	Start of Discharge

    b.   Erosion and sediment control plan (Part IIZ.C)
         (1)  Implement	Effective date of permit
         (2)  Reports	Semiannually, starting six months after the
                             effective date of the permit

    c.   Retention Pond Volume Reports	Annually by December 28th



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, any remedial actions taken,  and the
    probability of  meeting  the next scheduled requirement.
                                H-n

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(bknfc)
 H

-------
                                                      Part II
                                                      Page II-l
                              Part II

                 STANDARD CONDITIONS FOR NPDES PERMITS
  ggcriou a  rFfa»AT. rrrrmntn

                                                         P-,
P«n«lti.. ^ $2°sJJVo s*?/ nSJ™11*  COBdi*l°n  li  .Sbi..^.. P'rgon wh'
 •  <..                     ""™                   „
•
                       n-n

-------
                                                       Part n
                                                       Page n-2
                                                         •  —- — ^
    If th« pernitt«« b«liavB« t-K-*

   ^^^'^^^^^P^^S^SS1^^^^
  C  f+ t __ * «
    Civil «H1 ^rtni|pnl  U|ll|lKj,
 7.
                                                            :utio
8.

                                                              •*"'
                                                             v t;
                                              H-ZO

-------
                                                           Part ir
                                                           Page u-3
    11• Severabilltv

   12-
           to provide

               terminating this permit Sr
               The P««itt.«  sha^l  also  furnis
           upon request,  copies of recoV.Te^irea
                                                                    and
                                                                   with
«ppurt«n«ne«»)
           wih
                                                      and  fflaintain all
                                       nt  and   control  (and
 2.
                 th. condition, ct  h  p.t
         to B.lnt.ln
3.
   Definitions)
       •.tabli.h.d
                                                                    !TV

-------
                                                        Part n
                                                        Page 11-4
  *>• Bypas. not exceeding limitation..









    »»— . .»_ * _
    Notice

    (1) £!iciP"«d. byp««.
    '"
d- Prohibition of byp«M

   '"
                    dovntl,;   Thi.    nT,Uril!'  ner"«1  P«iods  o
                  backup •cuipB.nt .hoS?2  Jicn vU  not  «»tis£ied  I
                  of  r.«.on«M«  enoln^?. *V! ^n in«««U«l In the
                which occurred dur*in«  lB* ,^ud9«»«n«  to
                  or  r^                  1ltlod'  °f
                                                    und.r
                  n         a'
                              a- ( i) of this section.

                            H-2Z.

-------
                                                          Part xi
                                                          Page xi
      Uoaeta
  5-
 SECTION C.  MOIITWtp^ pap Rp^oppc.
 Samples   and
measurements
2- Plow



              ~                                     con.i.t.»t  with
        true, dltchaig* rate, tlurouah^^! deviation of  lea.  than ±10%
                           H-23

-------
                                       Part ii
                                       p«g« II-
   "'
     SD catalog No. 'cut" M!^""' "»««^toSJ D.i**Soi8
   (2) "Water Meaiurement Manual-  n v
                       '
            si-      »
             VA
  M)
           Federal Center  tnv.r, o. BO'JSS!" Sarvlc"' «»i"
 3-
           n8t „.   ,  »K   "0.000

5-
         sasSas^aw-sss-;-:

-------
       Record
    '•cor*. of ,o»itorlng
                            w.r.
                         vho
                                or
   7<
   The
             re.ult. of ,uch an.ly,!,
     b.  Have
    c.
    d.
1.
The p«raitte« •hall
                            H-ZS
                                                     Part n
                                                     Page 11-7

                                               asa v, -

-------
                                                             Part II
                                                             Page 11-9

    3- aanyftr of own..-..,!,. -r r-nm1

                b. autOB.tlcally
             .   if this
  effective on  the dat.
  paragraph b.
                                                            th.
                                                   or revoke  and  reiss::
                                              ,fec0ived'  th«  trans fe|
                                           in the. agreement- mentioned  I
               permit.
 See Part  in  O£  thi.


 5' ^d***°"fl1 MnnftePf.T ^ .^ rr,-,,,,,,,^
                                          increased frequency shall als
6. Av
Ca
 \H° ef°/n

issuing Authority  iVth"
                                              .vermin,

                                            °therwis«

-------
    Tventy-fnnr Hnup .-^^
                                         Page 11.9
                                          saw
 the
                         ._ any emu.nt
9.


The permittee
    <"°nehundred                         '
nJicrograms
11  ^-]

-------
                                                            Part  II
                                                            Page  ix-i:
               complete.   T »~ .....__ ^?*  an.a  Belief,  trua.  «,--.	*  ' cc
               of fine  and              for knowing violation* 5-
   14' ^mf^ for ral.iM^flTt^n nf p|||||||i










 SECTTQM P   DgPTVTTnr5

 :' Permit T^gulf^g ^^^y^^







«• _^ a

     ss-s:""^.

                          "V-'

-------
                       Part

    (1)
                         '
     ®^-£$£s&& ESj^^gfiSte

     SMawa^-^&s.'/S
 b.
               in


                   to the
c.

-------
                                                          Part ii
                                                          pag« II-
                                                          --yw Ai-


            '"
                                                  -»• -/ *.wt acroieln j
                                                  Z-IXZ:&°.««!

  a.
 Where EPA ia  th. p                     P«rn4.t expiration date.





                                        P"r"16 b'f°r
12.

^f i{application,
        Authority .naj.1 c« «iff««^i ..j~^r_w-w.".."»««i«t«a  to the  ?e~
                  .ppllCMlon.

-------
                                                       •Part II

                                                        Page 11-13
3.  Mass/Day

      I?? tfWff ^Cekly dlschar9«" i« defined as the total mass of

      Sik 2i SiSh^rfi9*'-?"1? 1-d and/°r oe"u"d during the calendar
      bv thS n^if^ ^J1^?1*^1?0* ar* '^P1^ »nd measured, divided
      such SeS^f*.  *f daiiy diachar9" sampled and/or measured during
                  It.1«' therefore, an arithmetic mean found by adding
                  of  °llutants found  each  day of the  week and
                  !
                column under -Quantity on the DMR.
           ma3clffl¥» d*ily discharge- is the  total  mas. (weight)  of

            an         r                              on(ly o9ne
    tak.n  dkn-r90   Ur?g 5 caland« d*y-  « only one    pie
cllcullted  ^ri™9*^ c!iendar  d*y  **• ^ight  of  pollutSnt
calculated  from it  is the  -maximum daily  discharae"    This

limitation  is  identified as  -Daily Maximum*, ia ^ Part  I of thl

P^tod l?££&m££*h.Fl?m ~o«toddi.S;«5f report ing
          "Parted in th« -Maxim-               -
     P                      £*.F?m ~o«todd.«  report ing
     the DKR?  "Parted in th« -Maximum- column under -Quantity en
 d.  The -aver**, annual discharge- is a rolling average equal to
                 .*« «*  +*-  mags  measured in all discharges
                               cona*cutiv«  reporting periods  which
                               *raMt«"  t"at  are measVred at least
                                ave"9« «ha^ *>• computed at the er.i
                                tO the arithffl«tic «•*« of the monthly

                            •

-------
  A                                        Part II

    Caa£9aSM"*ute««SfflaM,
















     «««S5££5-.SsS£S'.£15s
     Th« 'av«r-«^           «na«r "Quality of tiT^JL* repor~«
     h   *''"*• JO V^0)r)*>                '  * ^«0 OMR  r>»*. »«


                        —""• woxunn undA  —••»•** «uti

."
rt7. i?^""*1 "ne.ntr4tion.          T °" the cxs-
     «rt7. i?^""*1 "ne.ntr4tion.          T  °" the cxs-



-------
                                              Part It
                                              Pag« 11-15
5. Other

     ass sr jras" "" "      ••  »
 Tvpea of

    collection of th« previoaiiL'^i?? or total flow
    manually or automatically  *llquot ..... Al-iquot. may b« collected
                                                SB a
                                          — ""
   equivalent  to the ant i !«««*??     ?  geometric mean
                      H-33

-------
                                                         Part II
                                                         Page Il
  «  Calendar Da
                                                      ot
                                                                  s
9.
                                                     und«
1".  Toxle

-------
                                                Page  III-l
                                                Permit No. FL0041173
                                 Part III

  Jther Requirements

  A.  Reporting of Monitoring Results

  Monitoring results obtained for each calendar month shall be
  ?SS?aSiZe«aSd,fep°5Jed °2 a Discharge Monitoring Report (DMR) Form
  iuar^',  2    1'   J !Se  form8  sha11 be submitted after each calendar
  quarter and postmarked no later than the 28th day of the month
  following  +*» completed calendar quarter.  (For example, data for
                 »   Ti    8ubmitted bY April 28.)  Calendar quarters are
                 April-June,  July-September, and October-December.
  nf !>„•«. TT « ° these' and ftH other reports required by Section D
  ?L,,?   "'Reporting Requirements, shall be submitted to the Permit
  Issuing Authority  at the  following address:                   *«»«

                      Environmental Protection Agency
                      Region  IV
                      Enforcement Section
                     Water Permits and Enforcement Branch
                     Water Management Division
                      345 Courtland Street,  N.E.
                     Atlanta, GA 30365
 uce««    «                ,             be ao                ri
 upon cessation of discharge.  This notification shall be in writing

     Additional
                                             .            , "ut that no


 C*   Erosion and Sediment  Con^rnl
                                 SS
                                                            «»trol
contamina^dnof  su                  °rn  "S"116"8"^  for

of active
                                 H-35

-------
                                                Page III-2
                                                Permit No. FLO041173
 procedures shall be a part of this permit.  Control facilities to be
 used should include, but not necessarily be limited to, ponds
 swales, dikes, silt curtains, riprap barriers and use of minimal
 slopes.  Stabilization and revegetation (seeding sodding) of
 disturbed areas should be accomplished as soon as practicable after
 final grade is achieved.  Should construction phase runoff pose a
 implemented**6* quality' addi*ional measures shall be expeditiously


 A. resP°n8ible rePres®ntative of Cedar Bay Cogeneration Project (CBCP1
 snail be designated to supervise this program,  with necessary
 authority to expeditiously implement corrective action should
 problems be encountered.  To assure that the plan and all control
 X   £  * ar? in Pr°Per operation, this representative shall tour
 the site not less than once per week and during any significant
 rainfall event.   A permanent log of dates of observations,  dates  of
 entries, dates of actions,  corrective actions required,  actions
 taken,  and implementation of corrective  actions shall be maintained
 on site.

 D.   Erodible Material
The permittee shall not store coal, soil, nor other similar erodible
oSn!f lftl!« n * man?e? in which runoff is uncontrolled, nor conduct
construction activities in a manner which produces uncontrolled
   ^  5?   ! 8UCh uncontrolled runoff has been specifically approved
   the Director.  "Uncontrolled" shall mean without sedimentation
         ?  ?r ?ontr?ls approved by the Director.  This permit may be
         to include limitations for the discharge from such      Y
facilities, when installed.

E«  Detection Limits

If the concentration of a parameter is not detected usinc* the
applicable test method, the permittee shall report on the discharge
?22i^iSg*f P0?t.£orn« thf analvtical results as being measured It
iU! 5  ? ??e minimuin level for ^e test method selected; the test
method shall also be reported.

F-  Total Recoverable Metals and Phenolic Compounds Monitoy^ry

1.  For Outfalls 003 and/or 008, the following parameter shall be
    River?    durin9 discharge to Outfall. 001 thence the St. Johns


    Total Recoverable Copper,  Total Recoverable Zinc, Total
    Recoverable Mercury,  Total Recoverable Arsenic, Total Recoverable
    Antimony,  Total Recoverable Beryllium,  Total Recoverable Cadmium?
                                  Recoverable Nickel, Phenol,

-------
                                               Page III-3
                                               Permit No. FL0041173


 2.   For Outfalls  003  and/or 008, the following parameters shall be
     monitored during  emergency overflow discharge to the Broward
     Rivers

     Total Recoverable Copper, Total Recoverable Zinc, Total
     Recoverable Mercury, Total Recoverable Arsenic, Total Recoverable
     Antimony, Total Recoverable Beryllium, Total Recoverable Cadmium,
     Total Recoverable Lead, Total Recoverable Nickel, Phenol,
     Naphthalene,  Toluene, Biochemical Oxygen Demand (5-Day), Total
     Organic Carbon, Dissolved Oxygen, Total Kjeldahl Nitrogen,
     Phosphorus, and Oil & Grease


The monitoring period shall be defined as a six month period,
beginning on the  first day of discharge, or the time required to
obtain monitoring data from six discharge events, which ever occurs
first.  Based on  results, the permittee may request that the
monitoring frequency  for any of the above pollutants be reduced or
deleted.  EPA may modify the permit to-include an effluent limitation
or any other appropriate permit conditions, if at any time during the
monitoring period the sample data indicate that the effluent is
contributing to a Class III water quality standard violation.
                                  U-37

-------
./
f

                                                 '
SITE LOCATION - 1-MILE
       (JACKSONVILLE. FLORIDA
              • ••* i o
                                                    51

-------
JUL-22-1992  10:21 FROM   HER TflLLftHftSSEE          TO       ENU.PROT.flGENCY   P.02
       m  Florida Department of Environmental Regulation
           TWin Towers Office Bldg. • 2600 Blair Stone Road • Tallahassee, Florida 52399-240O

           Lavton Chiles. Governor                                  Carol M. Brownct. Secretary
                                 July  22, 1992
  Mr. James H. Scarbrough, Chief
  Water Permits and Enforcement Branch
  United States Environmental
    Protection Agency
  345 courtland street, Northeast
  Atlanta, Georgia  30308
                                    9
                       Re:  Waiver of State Certification
                            AES Cedar Bay, Incorporated/ Cedar Bay
                            Cogeneration Project
                            FL004X173

  Dear Mr. Scarbrough:

  On September 17, 1991, the EPA recjuested state certification of the
  draft NPDES permit for the AES Cedar Bay cogeneration facility
  discharges during construction located in Duval County, Florida
  (FL0041173).  This letter provides official notification that the
  state reaffirms its waiver of certification for this permit.  All
  ef fluent. Oimits_in. the NPDES permit are. at. least, as.-stringent as
  those specified in the state's permit for this facility.

  Although the Department issued a letter dated November 13, 1991,
  waiving certification, several changes have been made since that
  time to the draft NPDES permit.  Upon subsequent review of these
  changes, -the Department finds the modifications resulted in a more
  stringent set of monitoring requirements, thus sustaining the basis
  for the original waiver letter.

  If you have any questions regarding this facility, please contact
  Jan Mandrup-Poulsen at 904/488-4520. *
                                 Sincerely,
                                 tobert E.  Heilman, P.E., Chief
                                 Bureau of  Water Facilities
                                   Planning and Regulation
 REH/jmp

 cc:  Jerry Owen

-------
  %
   '< •no"
              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                               REGION IV

                          345 COURTLAND STREET. N.E.
                          ATLANTA. GEORGIA 3O365
                       FACT SHEET AMENDMENT
                                   RW^IVBD DURING
                                  - MARCH '18,  1992

                                             **
                   FEBRUARY o,

NPDES PERMIT NUMBER: FL0041173       DATE:

NAME OF APPLICANT: AES/Cedar Bay, Inc.
   to March IB, 1992.

               e
                                    .
  discharge from Outfall 003    §u«aiJP§Ji°able durin» Periods of
   Recoverable Antimmy  Total
   Recoverable Cadmira
           Phenol,
   Paoe ?-•>.
   additional 	
   discharge periods
   states:
 Total  Suspended Solids
 Total  Recoverable Copper
 ££*?•  ?ecove«*le Arsenic
 Total  Recoverable Beryllium
 Total  Recoverable Chromium
 Total  Recoverable Nickel
Naphthalene
Biochemical Oxygen Demand
Dissolved Oxygen
Phosphorus
                                        Arsenic ,  Total

                                         Be'llimn'
                                               T°tal  "«»~"M.
                                              «to
                                  P™™ i°:?ear' 24'hr "infall
                                  Broward River.  However, during
                                                  1 monitor for the
                                                  by grab sample:

                                    Total Recoverable Mercury
                                    Total Recoverable 2inc
                                    Total Recoverable Antimony
                                    Total Recoverable Cadmium
                                    Total Recoverable Lead
                                    Phenol
                                    Toluene
                                    Total Organic Carbon
                                    Total Kjeldahl Nitrogen
                                    Oil and Grease
                                                        Pnnieti on

-------
                                 -2-

    Unit of measure shall be mg/1 and the results shall "be attached
    to and submitted with the Discharge Monitoring Report form
    (DMR).  See Part III.F for additional permit conditions.

    Footnote jjj, which is referenced on page 1-1, was added-  It
    refers to the monitoring requirements for the metals and
    phenolic compounds on page 1-1.  It statess

    •Monitoring for this parameter is only required when a discharge
    occurs.*

c.  Paoe 1-3.  Monitoring requirements for Outfall 008 were added
    for the same pollutants listed in l.a. of this amended fact
    sheet.

d.  Pace 1-4. The same language mentioned in l.b. of this amended
    fact sheet was added.

e.  Page III-2.  Item E. was added.  It states:
                                      *

    •If the concentration of a parameter is not detected using the
    applicable test method, the permittee shall report on the
    discharge monitoring report form, the analytical results as
    being measured at less than the minimum level for the test
    method selected; the test method shall also be reported."

f.  Pace III-3.  item F was added.   It states:

    "1.    For Outfalls 003 and/or 008, the following parameters
          shall be monitored during discharge to Outfall 001 thence
          the St.  Johns River:

      Total  Recoverable Copper,  Total Recoverable Zinc, Total
      Recoverable Mercury, Total Recoverable Arsenic, Total
      Recoverable Antimony,  Total  Recoverable  Beryllium, Total
      Recoverable Cadmium, Total Recoverable Lead,  Total
      Recoverable Nickel,  Phenol,  Naphthalene,  and Toluene

    2.     For Outfalls 003 and/or 008, the following parameters
          shall be monitored during emergency overflow discharge to
          the Broward River:

      Total  Recoverable Copper,  Total Recoverable Zinc, Total
      Recoverable Mercury, Total Recoverable Arsenic, Total
      Recoverable Antimony,  Total  Recoverable  Beryllium, Total
      Recoverable Cadmium, Total Recoverable Lead,  Total
      Recoverable Nickel,  Phenol,  Naphthalene,  Toluene, Biochemical
      Oxygen Demand (5-Day),  Total Organic Carbon,  Dissolved
      Oxygen,  Total Kjeldahl Nitrogen,  Phosphorus,  and Oil & Grease

-------
                                  -3-

2.  Public Commen-fce
    comments received during the comment period'




3.  State
                  by letter dated July 22, 1992

-------
                          DISCEAR3E MCN1TORIN3 REPORT
                      GEMERAL PTgmxnCKS FOR
2* ^?P3£^0n f* ^Ported va1	^r
   tns conputiid values must be entered.

3- Quantity or. Loading, ti**
   is tte total of  the ~
  .calculated. 'measurejtBnt
                                       ? number of  dayji-iflurfng the-ionth  ti«
                                       mo  ea3m1a*-i:«We^*iii.'.vj.t-:_r_ _•-•-_.
                                                                 «»
 the OooitionC.)
     te inaicated on tte mR.
                                                    •
                                               .Knlt°ri"9.o£ jarareters at
                                                   the al^«'5 «»lytlcal
                                                incressecf fregiency feould
                                                MBasutMBat
minimum, 7-<3ay
Juried, including
enter "0".
                            and
                                   *•
                                               that €3CCBed (««d»am and/or
                                               f-nt. for each paranEterT
                                         exoepticns  during the  reporting
                                         limits,   if. none occurredTthsn
                                               «  .«port  »st  still
                                                th.  face  of tte  oat
                                 °HicB
                                                        copy  on  file  at

-------

-------
 '-I
 ' r.
UAME. /auY stlnson

ADDRESS AES/Cedar Bay^ Inc.
9469 East port Road ~" ' ~
Jacksonville, FL
FACIIITY AES/Cedar B.ay Cage
IOCATION Jack3£nvl_]jL_e_, FL

PARAMETER
H1-JJI
LOW, IN CONDUIT OR
'HRU TREATMENT PLANT
.0050 1 0
:FFLUENT GROSS VALUE
OLID3, TOTAL
USPENDED
10530 1 0
:FFLUENT GROSS VALUE
'M
10400 1 0
:FFLUENT GROSS VALUE
'otal Recoverable
lopper
11119 1 0
:FFLUENT GROSS VALUE
IERCURY
'OTAL RECOVERABLE
1901 1 0
AFFLUENT GROSS VALUE
VRSENIC, TOTAL
tECOVERABLE
10978 1 0
AFFLUENT GROSS VALUE
ANTIMONY, TOTAL
RECOVERABLE
11260 1 0
IFFLUENT GROSS VALUE
nera
\>z
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
MEASUREMENT
PERMIT
REQUIREMENT
TYPED OR PRINTED

tlon ProJec



OISCHAF
a-i
UIITORINO REPORT fl»W 	 "*
(17-191
PeWtWT NUM9CN

FROM
•

003 1
DISCHARGE NUMBER
MONITORING PERIOD
YEAR
aa-tn
MO
111-1)1
DAY I
1
OCfrHOnlrl QUANTITY OR LOADING
AVERAGE
********
********
********
********
********
********
********
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********
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r
********
********
********
********
MAXIMUM



REPORT
INST MX
********
********
********
********
********
********
*********
********
********
********
********
********
UNITS
MGD

***
***

*
*
****
****
****
****
****
****
****
****
****
****
TO
YEAR
iM-in
MO 1 DAY
M-lvi tin. in
FINAL '^"

i
MINOR !
NOTE: RMri httlruef Ion* turfat* MmnUflM IKU f~—
r«OrfOnfr; QUALITY OR CONCENTRATION
a*-*» f**-.«» (u*ii
MINIMUM
********
******
**
********
**
**
**
**

6.5
MINIMUM
********
**
******
********.
********
********
* *
* *
****
********
********
AND AM FAMILIAR WITH THE INFORMATION SUBMITTED HEREIN AND BAS
ON MY INQUIRY OF THOSE INDIVIDUALS IMMEDIATELY RESPONSIBLE Ft
OBTAINING THE INFORMATION 1 BELIEVE THE SUBMITTED INFORMATIC
5JE"1' *CCURATE AND COMPLEIE. 1 AM AWARE THAT THERE ARF SI
NIFICANT PENALTIES FOR SUBMITTING FALSE INFORMATION. INCLUDIK
THE POSSIBILITY OF FINE AND IMPRISONMENT SEE III U.SC. 1 WOI AH
ll^USC. 1 tin. fPMMn in*** (ftrv iMfMn m«» m,lmtr fmn if M |/l».(1
D
)R
IN
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m

AVERAGE
********
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MAXIMUM
********
***•*»**»-

50 	
INST MX

8.5
MAXIMUM

REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

SIGNATURE OF PRINCIPAL EXECUTIVE
OFFICER OR AUTHORIZED AGENT



.UNITS
****
****
MG/L
SU
MG/L
MG/L
MG/L

MG/L

NO
na-u














TELEPHONE




FREQUENCY
OF
fM-MI


WEEKLY

WEEKLY

WEEKLY

ONCE/
2 WEEK J

ONCE/
2 WEEK*


ONCE/
2WEEKJ

ONCE/
2 WEEK I



SAMPLE
TYPE

PMPLOC

GRAB

GRAB

GRAB

GRAB

GRAB

GRAB
DATE





                                                                                                                    :  '
w    This outfall  has  an Intermittent discharge to Outfall 001.

-------
  .N«ME_     am  stlnson
  *PD«ESS_  *BS7Ce"da"r"~Bay7 Trie".	
             S	
                     uiaonnm
                        tl 1*1
                   NIIUHINU HtPURTfOMAV
                                llt-lt)
                                                      FINAL
                                                                                              NOTE: R««d hnlruclHMM Won compltllno Ihti form.
                                                                                              '**^»*»^	   	
           r__1JI^^^^^
          QUANTITY OR LOADING
               IH.IHI
                                                                                   QUALITY OH CONCENTRATION
  lERYLLIUM,  TOTAL
  ECOVERABLE (AS BE)
  0998       1     o
                                                          HtiPUHT
                                                         INST MX
  :FFLUENT GROSS  VALUE
                                                                    3NCE7
                                                                    2 WEEK
  :ADMIUM
  OTAL  RECOVERABLE
  1113       1
********

********
********

********
  FFLUENT GROSS  VALUE
  EAD
  OTAL RECOVERABLE
  1114       1      0
 AFFLUENT GROSS  VALUE
  ICKEL,  TOTAL
  AS  NI)
  1067      1
  FFLUENT GROSS  VALUE
  INC
  OTAL RECOVERABLE
  1094      1      0
   _ T GROSS  V
 [lAPHTHALENE
                                                          REPORT
                                                        INST MX
 :FFLUENT  GROSS VALUE
 AFFLUENT  GROSS VALUE
                                                                               ONCE/
                                                                               2 WEEK
  NAMEfTITLE PRINCIPAL EXECUTIVE OFFICER
          TYPED OR PRINTED
                                 I CERTIFY UNDER PENALTY OF LAW THAT
                                 tSPiirZmSiriyi" ™E WW»M«ON ^>mif>tm ANBASEO
                                 2UTM.L?!00."'r <* THOSt IMWVtOUALS IMMF.DIAIH Y nESPONSIRLE FOR
                                 OBTAININO IHE INFORMAtWH I BELIEVt THE SUBMITtEO INtORMATION
                                         11*'1 *MO COWttE. I AM AWARE tHAf tMERIi ARE SW
                                             fOR SUBMIIIINO TALSE INrORMAtKW INCLUDINa
                                               *MI>'    s"
 COMMENT AND EXPLANATION OF ANY V1OWTIONSf*,/W»W*«r«*
This outfall has  an intermittent discharge to Outfall  001
                                      SIGNATURE OF PRINCIPAL EXECUTIVE
                                       OFFICER OR AUTHORIZED AGENT
                                                                                                             NUMBCR
                                                                               TEAR
                                                                                     MO
                                                                                         OAT
                                                                                                                                         I I
                                                                                                   1 '
 EPA Form 3320-1 (Rwr. M8) ftwftwt »dltlon$ me? to
                                                    REPLACES EPA rONM t-40 WHWN MAY NOT «E USEOJ
                                                                                                                      PAOE

-------
    I  _
      I*
C    iP?*!!2M_Jaji
e!
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c!
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oi
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    \

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NAN Paul stlnoon
ADD»« AES/Cedar Bay
9469 East port
^""•^^» ^™» ^B^ v_ «•• B^M ••••• Aa «^»«i
.T^r* It /mwr«0«Mr*mwn Anr/
This outfall has an Intermittent discharge to
Outfall
FINAL


MINOR
f«C«n/0«/i? DUALITY OR CONCENTRATION
MINIMUM
********
********






^





AVERAGE
********
********












XAMINFD
ID RASED
RLE FOR
RMATION
ARE SK>
2°tM m SIGNATURE OF PRINC
" '""" OFFICER OR AUTW
001.
MAXIMUM

REPORT
INST MX













IPAL EXECUTIVE
JRIZED AGENT


UNITS
MG/L










NO.
EX
ra-»3i














TELEPHONE


t
NUMBER
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OF
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NCV
SIS
•/

ONCE/
2WEEK!





.

-•

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SAMPLE
TYPE

GRAB

i

',



i

i

•
DATE

YEAR


MO DAY

                                                                                                                            I
                                                                                                                           i,
      EPA Form 3320-1 (Rm. 948) Pnrtout trf/Mm* m«r b* mtd.
(MCnACES EPA FONM I-4« WHICH MAT NOT M UKO)
                                                                                                            nun 3  OF

-------
'' I
  3
  *
ttiuuw «,„• II iW/rrrml
NAME ?aul Stlnson
ADDRESS AES/Cedar Bayr Inc
9469 Eastport Road






Jacksonville, FL 32218
FACILITY AES/Cedar Bay Coqei
LOCATION Jacksonville* FL
..
PARAMETER
m-nt
OLIDS, TOTAL
USPENDED
10530 1 0
:FFLUENT GROSS VALUE
:OPPER
•OTAL RECOVERABLE
U119 1 0
IFFLUENT GROSS VALUE
IERCURY
•OTAL RECOVERABLE
1901 1 0
:FFLUENT GROSS VALUE
kRSENIC, TOTAL
JECOVERABLE
10978 1 0
:FFLUENT GROSS VALUE
VNTIMONY, TOTAL
tECOVERABLE
)1268 1 0
IFFLUENT GROSS VALUE
IERYLLIUM, TOTAL
tECOVERABLE (AS BE)
)0998 1 0
:FFLUENT GROSS VALUE
:ADMIUM
•OTAL RECOVERABLE
)1113 1 0
:FFLUENT GROSS VALUE
ie;r.atJL0.IL Pi pjlej
X
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
'SAMPLE
MEASUREMENT
PERMIT '
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
NAMEHITLE PRINCIPAL EXECUTIVE OFFICER

TYPED OR PRINTED
c
FR<
)M
— -jj.
FL004.* . 3
— 1
PERMIT NUMBER |
	 . ,.,, .' 	
" f7>-'/»;


003
2
DISCHARGE NUMBER

MONITORING PERIOD
YEAR

MO | DAY |
TO

OCfnlOnlfl QUANTITY OR LOADING
AVERAGE
********
********
********
********
********
********
********
********
********
********
********
********
********
********
1 CERTIFY UNDER PENALTY Ol
AND AM FAMILIAR WITH THE II
ON MY INQUIRY OF THOSE I*
OBTAINING THE INFORM A HO
IS TRUE. ACCURATE AND CO*
NIFICANT PENALTIES FOR Stl
THE POSSIBILITY OF FINE AN
33 U.SC. 1 <3lt rrhMlHn m

MAXIMUM
********
********
********
********
********
********
********
********
********
********
********
********
********
********
T LAW THAT
•FORMATION
IDWIDUALS 1
M 1 RELIEVE
4PIETE. 1 AN
BMITTING F
) IMPRISON*
•mm A flM«*r*«
UNITS
** **
** **
****
****
****
****
****
****
****
****
****
****
****
****
YEAR

(}*ir>
IH-4JI
MO

tu-iv
DAY

<)(l)l>
FINAL
MINOR


NOTE: Reed Instruction* before completing thl* form.
QUALITY OR CONCENTRATION
MINIMUM
********

********
********
********
********
********
********
********
********
********
********
********
********
1 HAVE PERSONALLY EXAMINED
SUBMITTED HEREIN. AND BASED
MMEDIATEIV RESPONSIBLE FOR
THE SUBMITTED INFORMATION
1 AWARE THAT THERE ARE SKI
USE INFORMATION. INCLUDING
IENT SEE IdUSC 1 1001 AND
tn m*f >iih* /ton wf m llt.Ono
AVERAGE
********

********
********
********
********
********
********
********
********
********
********
********
********
MAXIMUM

REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

REPOR
INST M

SIGNATURE OF PRINCIPAL EXECUTIVE
OFFICER OR AUTHORIZED AGENT
T
X
UNITS
MG/L

MG/L
MG/L
MG/L

MG/L

MG/L
MG/L

NO.
EX
rtl-tJ,














TELEPHONE

AREA
CODE

MUMKN
FREQUENCY
OF
ANALYSIS
1M-MI

ONCE/
DSCHD\

ONCE/
DSCHD1

ONCE/
DSCHD1

ONCE/
DSCHD1

ONCE/
DSCHD1

ONCE/
DSCHDT

ONCE/
DSCHD1


YEAR
SAMPLE
TYPE

GRAB

GRAB

GRAB

GRAB

GRAB

GRAB

GRAB
DATE

•O DAY
                                                                                                                                             r
       COMMENT AND EXPLANATION OF ANV VIOLATIONS (*rfm*tt*U»IUr>ii>mn>im>
       This  outfall  has  an Intermittent discharge to  the  Droward  River during  storms In  excess  of the 10Y24H event
                  t

                  4

                  4
       EPA Form 3320-1 (Rev. 9-88) Pnvlous editions m«r 6e used.
                                                          (REPLACES EPA FORM T-«0 WHICH MAT NOT BE USED.)
MOE

-------
 If    -
_J    £P!
51
-i
  o
  I
	.    !&TjLUjiJL°JL	
M>DRESS_  AES/Cedar Bay, _I/i£.	'
	i,_FL_	
jFAciLrTT_  AES/Cedar Bay Coqene_rat_l_orj_ Projec
 LOCATION  Jacksonville. FL
                                                                OlSCHAf.'
                                                                   «•»*.
                                                                    '(TORINO REPORT r/MW
                                                          FROM
FL004H»J
PERMIT NUMBER



003
2
DISCHARGE NUMBER

MONITORING PERIOD
YEAR | MO
1
DAY


IYEAR

MO

DAY

                                                                   HI-HI
                                                                                      (M-J9I 130-MI
                                                                                          FINAL,
                                                                                                 MINOR
                                                                                                  NOTE: RMd hwtnicttons b«for» completing IMs form.
PARAMETER
w-m
.BAD
'OTAL RECOVERABLE
11114 1 0
:FFLUENT GROSS VALUE
IICKEL
•OTAL RECOVERABLE
)1074 1 0
:FFLUENT GROSS VALUE
:INC
'OTAL RECOVERABLE
11094 1 0
AFFLUENT GROSS VALUE
:HROMIUM
'OTAL RECOVERABLE
)1110 1 0
AFFLUENT GROSS VALUE
'OLUENE
14010 1 0
AFFLUENT GROSS VALUE
IAPHTHALENE
54696 1 0
AFFLUENT GROSS VALUE
'HENOL3
16000 1 0
AFFLUENT GROSS VALUE
X
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
NAMEfTITLE PRINCIPAL EXECUTIVE OFFICER

TYPED OR PRINTED
t)C*n!O*l*) QUANTITY OR LOADING
f«-J>; 04-MI
AVERAGE
********
********
********
********
********
********
********
********
********
********
********
********
********
********
1 CERTIFY UNDER PENALTY O
AND AM FAMILIAR WI1H THE II
ON MY INQUIRY Of THOSE 1'
OBTAINING THE INFORMATIO
IS TRUE. ACCURAIE AND CO
NIFK2ANT PENALTIES FOR SI
THE POSSIBILITY OF FINE AN
jj use I in* rrvn«(M« M

MAXIMUM
********
********
********
********
********
********
********
********
**#*****•
********
********
********
********
********
UNITS
****
****
****
****
****
****
****
****
****
****
****
****
****
****
<4Cord<>*M QUALITY OR CONCENTRATION
«•-«; r*«-5.»; 
-------
n
i
  w
 •J
  i
   \
  en
  o
ftrtwi 'MC/ADDNESSfferiMt NATK
ADDRESS AES/Cedar Day, Inc.
~9TWEastport fioaZ
^^ """" "™" """*« T"™ *~~ "*™1 *1 «~"~ "~"-.T~ T1* *^^ "•"• — — ••• •»-» ...
JacKsonvllle, FL T
FACILITY AES/Cedar Day Cogc
LOCATION Jacksonville, FL

PARAMETER
Ui-W
IOD, 5-DAY
20 DEG. C)
10310 1 0
:FFLUENT GROSS VALUE
.ARDON, TOT ORGANIC
TOC)
• 0600 1 0
:FFLUENT GROSS VALUE
)XYGEN, DISSOLVED
DO)
10300 1 0
:FFLUENT GROSS VALUE
IITROGEN, KJELDAHL
'OTAL (AS N)
)0625 1 0
:FFLUENT GROSS VALUE
'HOSPIIORUS, TOTAL
AS P)
)0665 1 0
AFFLUENT GROSS VALUE
)IL AND GREASE
i-REON EXT-GRAY METH
)0556 1 0
AFFLUENT GROSS VALUE


12218
inera_tTon_ JPr ojec
FRC

X
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT

TYPED OR PRINTED
f.
CHARGE ELIMINATION SYSTEMfWOEJI
ONITORINQ REPORT fDMM ^^
e 17. 19i
FL004H73 1
PERMIT NUMBER |
>M
OUJ 2
DISCHARGE NUMBER
MONITORING PERIOD
YEAR
(IQ-Ht
MO
L— J
11 Cfnl Onfyf QUANTITY OR LOADING
AVERAGE
********

********

********
********
********
********
********
******** .
******** '
********


MAXIMUM
********

********
********
********
********
********
********
********
********
********
********


AND AM FAMILIAR WITH THE INFORMATION S
ON MY INQUIRY OF THOSE INDIVIDUALS IM
OBTAINING THE INFORMATION 1 BELIEVE
IS TRUE. ACCURATE AND COMPLETE 1 AM
NIFICANT PENALTIES FOR SUBMITTING FA)
THE POSSIBILITY OF FINF AND IMPRISONMF
39 U.SC 1 13 It rfViMMrt mmtrr ffcrw tivnw
••Nf «v 0MUMWM ttmjittHmmiKl of fti tmffn H Mwwvrft* OT
DAY
w-ni

UNITS
ft**
***
***
***
*
*
*
*
****
****
****
****
ft***
****
****
****

4lflMIMFDHEREIN
MEWATEIY RFSPC
'HE SUBMITTED II
AWARE IHAT THF
SE INFORMATION
Nl SEE III USC
« mtf Mr** /mft


TO
YEAR
IM.
(4C*rdt)nl
-------
4
1
-i

   \i\
NAME*"" a'uY s'tinson
ADDRESS. AES/Cedar Bay
9467 Eastport
L Inc
R~oaor
Jacksonville, FL
FACILITY AES/Cedar Bay Coqe
LOCATION Jacksonville, FL
PARAMETER
'LOW, IN CONDUIT OR
•HRU TREATMENT PLANT
iOOSO 1 0
AFFLUENT GROSS VALUE
lOLIDS, TOTAL
SUSPENDED
)0530 1 0
AFFLUENT GROSS VALUE
Ml
10400 1 0
AFFLUENT GROSS VALUE
'otal Recoverable
Topper
)1119 1 0
AFFLUENT GROSS VALUE
1ERCURY
'OTAL RECOVERABLE
71901 1 0
AFFLUENT GROSS VALUE
VRSENIC, TOTAL
IECOVERABLE
30978 1 0
AFFLUENT GROSS VALUE
ANTIMONY, TOTAL
IECOVERADLE
)1260 1 0
AFFLUENT GROSS VALUE

.


"-"-----
"X"
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
NAMEHITLE PRINCIPAL EXECUTIVE OFFICER

TYPED OR PRINTED
c
F«


"'""f2~W
FL0041-
••i wnmu ncf
PERMIT NUMBER |
)M

""'""?,",'„
008
1
1
DISCHARGE NUMBER

MONITORING PERIOD
YEAR
fin. MI
MO

rjc«n/n»i/r; QUANTITY OR LOADING
»•«-.«; M-MI
AVERAGE
********
********
********
********
********
********
********
********
********
********
********
********
********
********
MAXIMUM

REPORT
INST MX
********
********
********
********
********
********
*********
**'******
********
********
********
********
DAY
/M.MI

UNITS
MGD

****
****
****
****
****
****
****
****
****
****
****
****
1 CERTIFY UNDER PENALTY OF LAW THAT 1 HAVE PERSONA)
AND AM FAMILIAR WITH THE INFORMATION SUBMITTED HERE
ON MY INQUIRY OF THOSE INDIVIDUALS IMMEDIATELY nESt
OBTAINING THE INFORMATION 1 BELIEVE THE SUBMITTED
IS TRUE. ACCURATE AND COMPLETE. 1 AM AWARE THAT TH
NIFICANT PENALTIES FOR SUBMITTING FALSE INFORMATTO
THE POSSIBILITY OF FINE AND IMPRISONMFNT SEE III USC
XI USC 1 1311 /fVMftOT •"<** >*r» iKMin met lnlWr /Mr


TO
YEAR MO

f.M'.V

DAY

FINAL
MINOR
NOTFrRmillfi
•Imellan* halnm MMHnlatlnM iMm f MMM
QUALITY OR CONCENTRATION
MINIMUM
********
********
********


6.5
MINIMUM
********
********
********
********
********
********
********

.LY EXAk
N; AND B
•ONSITHE
INroRM«
ERE ARE
N. INCLU
1 1001
t «p M J
IINED
ASEO
FOR
TION
SK>
IOING
AND
W.OtW

AVERAGE
********
********
********
********
********
********
********
********
********
********
********
********
ft*******

MAXIMUM
********
****** **

50
INST MX

8.5
MAXIMUM

REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

SIGNATURE OF PRINCIPAL EXECUTIVE
OFFICER OR AUTHORIZED AGENT
UNITS
****
****
MG/L

GU
MG/L

MG/L

MG/L
MG/L

NO.
EX














merMONc

AHEJI
COPI

NUMBCM
FREQUENCY
OF
ANALYSIS
fM-W

WEEKLY

WEEKLY

WEEKLY

ONCE/
2 WEEK I

ONCE/
2 WEEK I

ONCE/
2 WEEK:

ONCE/
2WEEK!


YEAN
SAMPLE
TYPE

PMPLOC

GRAB

GRAB

GRAB

GRAB

GRAB

GRAB
DATE

MO DAY
                                                                                                                                                    • II
       COMMENT AND EXPLANATION OF ANY VIOLATIONS (Kr/rma *tt ttarlimnHi ftrrr/

      This  outfall  has  an  Intermittent  dlncharge to Outfall  001.
       EPA Form 3320-1 (R«v. 9418) nwtoi/s ttfWon* m«r ft* »••
-------
JMME FdUjL bcinson
MOM. AES/Cedar Baj^ Inc.
9469 EaatjBprt Road
Jacksonville, FL
fAcniTY AES/Cedar Bay Coqeneratlon Projcc
LOCATION ^JflckSOnvJile. FL FRf

PARAMETER
JERYLLIUM, TOTAL
! ECO VER ABLE (AS BE)
)0998 1 0
:FFLUENT GROSS VALUE
./iDnlUM
•OTAL RECOVERABLE
11113 1 0
IFFLUENT GROSS VALUE
.EAD
•OTAL RECOVERABLE
)1114 1 0
AFFLUENT GROSS VALUE
UCKEL, TOTAL
AS NI)
)1067 1 0
SFFMIF.NT GROSS VAMIF
:INC
•OTAL RECOVERABLE
J1094 1 0
^.FFI.IIF,NT GROSS VAMIF
IAPHTIIALENE
J4696 1 0
AFFLUENT GROSS VAMIF
TOLUENE
MOID 1 0
'FFMIPNT GROSS VAT.IIF

X
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT •
SAMRJ.E
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT

TYPED OR PRINTED
FLOOs ,3
PPHHIT ttuttmrm
)M
YEAR
(10111
M
MO

ONITO
DAY

W c*« fJMr; QUANTITY OR LOADING
AVERAGE
********

********
********
********
********
********
********
********
********
********
********
********
********
MAXIMUM
********
********
********
********
********
********
********
********
********
********
********
********
********
ft*******
I «H!WT UNDER PENALTY OF LAW THA
AND AM FAMILIAR WITH THE INFORMAIIO
ON MY INQUIRY OF THOSE INDIVIDUALS
OBTAINING THE INFORMATION 1 BtllEV
is TRUE. ACCURATE AND COMPLETE 1 1
NIFICANT PENALTIES FOR SUBMITTING
THE POSSIBILITY OF FINE AND IMPRISO*
33 U.SC. 1 131* rriMAin ««*» Mrv  *f M lltt.m
COMMENT AND EXPLANATION OF ANY VIOLATIONS HttfrnmtMau^m^K hrrr,
This out£all has an Intermittent discharge to
Outfall
001.

9
>
n
«
)
n

AVERAGE
********
' ********~
********
********
********
********
********
********
********
********
********
********
********
********
MAXIMUM

REPORT
INST MX


REPORT
INST MX


REPORT
INST MX


REPORT
INST MX

REPORT
INST MX

REPORT
INST MX

REPOF
_LNST >

SIGNATURE OF PRINCIPAL EXECUTIVE
OFFICER OR AUTHORIZED AGENT

IT
X,
UNITS
MG/L

MG/L

MG/L
MG/L
MG/L

MG/L

MG/L

NO
fftM


•••••M








TELEPHONE
1 .
ipmm
FREOt
O
ANA1
n»
•HB^H
glhli
«NC
f
YSW
**>
ONCE/
2WFFK

ONC
2WE
E/
FV

ONCE/

ONCE/
'WEEK
ONCE/


ONCE/
ZWEEK*
ONCE/
WEF"'



llomi.
•— •— MHBH^
SAMPLE
TYPE
(&9'7Df
-i^»«™ ^«— M
GRAB

GRAB

GRAB

GRAB
•••••IBIM^MB^
GRAB
^^•••(••^^^M
GRAB
^^•••^^HHII^
GRAB
DATE


                                                                                                                                                                                  G
EPA Form 3320-1 (R«v. 948) fYtvfoua «tf/ffont m»y b* utfd.
                                                                   IREPLACES EP* FORM T-W WHICH MAT NOT BE USED.)

-------
H
•£*££- P-sujtl. -S-U-nson.
	 9A63-EA&1 c jrt RruuL
.FACILITY 	 AEfi/roH^i- ga.,
LOCATION TarkgonuLLLc.*
FAMAMmft
'IIENOLS
16000 1 0
vKFLUFNT GPft79 VAt/Uff







NAMCfTITLE PRINCIPAI FVFdfTivEnc
-EL.
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAOVlE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PER*
REQUIRE

, TYPED OR PRINTED
«T
MENT

FROM
7Tt«rrf»r 1-ir.t •'wLniiunar"r/cr»K*«ff«r(«r*mninkrn>y
This  out£all has an  Intermittent  discharge  to  outfall 001
EPA Form 3320-1 
-------
                                                            NATIONAL POLLUTANT r-
                                                                 DISCHARO'
                                                                    fJ-M/
••OE ELIMINATION SYSTEM (HPOfS)
 3RIMO REPORT (liMKI
.1

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 i
\
ADDRESS AES/Cedar Bay. Inc.
9 4 62. EastfcorjL
JacJcsonvUJLs*.
FACILITY AES/Cedar Bav

-Road
_FLJ
_C_o_g£
FL

-22U... .,
AfiXflJtlojL .Prp4e.c
F«
FL0041173 1
PERMIT NUMBER |
)M

PARAMETER
IOLIDS, TOTAL
SUSPENDED
J0530 1 0
AFFLUENT GROSS VALUE
:OPPER
'OTAL RECOVERABLE
J1119 1 0
AFFLUENT GROSS VALUE
IERCURY
•OTAL RECOVERABLE
71901 1 0
AFFLUENT GROSS VALUE
VRSENIC, TOTAL
RECOVERABLE
)0970 1 0
AFFLUENT GROSS VALUE
\NTIMONY, TOTAL
RECOVERABLE
11268 1 0
rFFMiF.MT npnns VAT.IIF
JERYLLIUM, TOTAL
RECOVERABLE (AS BE)
J0990 1 0
^FFMIF.NT mnRS VALUE
:ADMIUM
'OTAL RECOVERABLE
J1113 1 0
-FFI.IIFNT r.nrtr.r. VAT.IIF.
X
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REQUIREMENT
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REQUIREMENT
NAMEHITLE PRINCIPAL EXECUTIVE OFFICER

TYPED OR PRINTED
008
2
DISCHARGE NUMBER
MONITORING PERIOD
YEAR
MO
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DAY 1
-^H TO
1
(JCfrannlfl QUANTITY OR LOADING
AVERAGE
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1 CERTIFY UNDER PENALTY OF t*W THAT
AND AM FAMILIAR WITH THE INFORMATION
ON MY INQUIRY OF IHOSE INDIVIDUALS Ik
OBTAINING THE INFORMATION 1 BELIEVE
IS TRUE. ACCURATE AND COMPIEIE. 1 AM
NIFICANT PENALTIES FOR SUBMITTING FA
THE POSSIBILITY OF FINF AND IMPRISONM
33 U.S.C. 1 131* r/WM* •*•** rtnr wim

UNITS
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ENT SEE INUSC
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IV EXAMINED
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SIGNATURE OF PRINCIPAL EXECUTIVE
OFFICER OR AUTHORIZED AGENT
COMMENT AND EXPLANATION OF ANY VIOLATIONS IKtftmn •# MMrAmnin hrrrl

T
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UNITS
MG/L

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Mf-41














TELEPHONE

CODE
t
MVMKN
FREQUENCY
OF
ANALYSIS
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ONCE/
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ONCE/
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ONCE/
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ONCE/
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YEAR

SAMPLE
TYPE
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GRAB

GRAB

GRAB

GRAB

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GRAB

GRAB
DATE

MO OAT

      This  outfall has an Intermittent discharge  during  storms  In excess of the 10Y24  rainfall  event,
      EPA Form 3320-1 (R«v. M8) Pnvtwit •tf/r/on* m»r o» u$9d.
                                                          (RtriACES EPA FORM T «O WHICH MAY NOT BE USED.)
                                                                                                                             PAGE

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 I    r=
     NAME
 I    -ADDRESS
i    izr
   I	0
                                                              DISCHAROF
                                                                 tt-IV
                                                                        TORINO r:,
ADDRESS _i££/CedaA Hay^ JLnc .
JaeleponvM IP. FTi ^
FACILITY AES^Cedar; R.ay Cogc
LOCATION .lArk.tnnvl 1 1 P FL
PARAMETER
m-m
,EAD
•OTAL RECOVERABLE
)1114 1 0
-FFMIF.MT nnOSfi VAT^JF,
IICKEL
'OTAL RECOVERABLE
)1074 1 0
^FFT.UF.NT mnRR VAMIE
:INC
'OTAL RECOVERABLE
J1094 1 0
-FFMIENT r.anr.x VAMIP
:HROMIUM
'OTAL RECOVERABLE
)1118 1 0
vFFMIF.NT nnORS VAMIC
TOLUENE
MOID 1 0
AFFLUENT GROSS VALUE
NAPHTHALENE
54696 1 0
AFFLUENT GROCC VALUE
•HENOLS
16000 1 0
r.FFMIF.NT KttnRR VAMIE
ncraflnn PrnH*>i~


FROM
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REQUIREMENT
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SAMPLE
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PERMIT
HEOUIMLMENT
NAMEftlTLE PRINCIPAL EXECUTIVE OFFICER

TYPED OR PRINTED
FL0041* j I
PERMIT NUMBER 1
1 008 2
1 DISCHARGE NUMBER
MONITORING PERIOD
YEAR
MO 1 DAY 1
1 |'«
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AND AM FAMILIAR WITH THE »
ON MY INQUIRY OF THOSE IN
OBTAINING THE INFORMATIOI
IS TRUE. ACCURATE AND CO*
NIFICANT PENALTIES FOR SU
THE POSSIBILITY OF FINE AM
13 USC 1 nit 0VMMM .*

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HAVF. PERSONALLY EXAMINED
SUBMIT TtO HEREIN; AND BASED
«MEOIA!FIV RESPONSIBLE FOR
THE SUBMITTED INFORMATION
AWARE THAT THERE ARC SIG
ISE INFORMATION. INCLUDING
ENT SEEW USC. 1 1001 AND
t* MffP Mfferif fiHfl Up A» IM.AM
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REPORT
INST MX

REPOfl
INST H

SIGNATURE OF PRINCIPAL EXECUTIVE
OFFICER OR AUTHORIZED AGENT

T
X
UNITS
MG/L

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TELEPHONE


B
NUMBER
FREOUI
OF
ANALV
flWJI
inn
NCY
SIS
n

ONCE/
DSCHD1

ONCE/
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ONCE/
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ONCE/
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ONCE/
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ONCE/
DSCHH'


YEAR
SAMPLE
TYPE

GRAB

GRAB

GRAB

GRAB

GRAB

GRAB

GRAB
DATE

MO DAY
                                                                                                                                         III
c
I
I
  i
     Thlo  outfall  has an Intermittent  discharge  during storms  In  excess o£  the  10Y24  rainfall  event,
     EPA Form 3320-1 (R«v. W8) Prmrfcwt tdlllont may ft* usvtf.
                                                        mcnAccs EPA FORM T-W WHICH MAY NOT •< wscoj
                                                                                                                        MOC
     r«rf*>» Mmr/UraMM (fx
     2«A««E_._P.a_ul. ^.tils.°Jl	
     ADDRESS   AES/Cedar  Ba^y^ JLnc.	
                                                        NATIONAl POUUTANT CHSCHAROE EllMINATION SYStf M WPPES>
                                                             DISCHAROEMONITORINQ REPORT fDMW
                                                            FL0041173   I    I  008 2
                                                                                             FINAL

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•I
   I
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.NAME"* fa uTH't 1 ns on
•AOOHE. AES/Cedar BayA Inc.
9469 Eti^fcnnrt Rn^arl
m,_ Jacksonville. FL 32218
LOCATION 	 Jacksonv l_l_l_e FL

PARAMETEtt
JOD, 5-DAY
20 DEC. C)
)0310 1 0
AFFLUENT GROSS VALUE
:ARBON, TOT ORGANIC
TOO
)0680 1 0
IFFLUENT GROSS VALUE
>XYGEN, DISSOLVED
DO)
)0300 1 0
IFFLUENT GROSS VAQUp
IITROGEN, KJELDAHL
•OTAL (AS N)
10625 1 0
AFFLUENT GROSS VALUE
•HOSPHORUS, TOTAL
AS P)
)0665 1 0
~FFT.IIF.NT RRnSS VAT. lip
)IL AND GREASE
^REON EXT-GRAY METH
)0556 1 0
•IFFLUENT GROSS VALUF


FRC

X
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MEASUREMENT
PERMIT
REQUIREMENT
TYPED OR PRINTED


>M
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FL004.
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MONITOR
YEAR
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NO REP
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TO
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1 CERTIFY UNDF.R PENALTY OF LAW THAT 1 HAVE PERSONALLY EXAMINE
AND AM FAMILIAR WITH THE INFORMATION SUBMIITED HEREIN AND BASE
ON MY INQUIRY OF THOSE INDIVIDUALS IMMEDIATE! V nFSPONSIRLE FO
OBTAINING THE INFORMATION 1 BELIEVE THE SUBMITTED INFORMATtO
IS TRUE. ACCURATE AND COMPLETE 1 AM AWARE THAT THFRE ARE SIC
UK!0.!!" "NM.TIM FOR SUBMIMINO MLSE INFORMATION. INCLUtHN
THE POSSIBILITY Or TINE AND IMPRISONMENT Sft III USC 1 1001 AN
31 U.SC. « IJI« rrr
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          1
          I?       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                    REGION IV
                              345 COURTLAND STREET. N.E.
                               ATLANTA. GEORGIA 3O365
                            RESPONSE TO COMMENTS
                    AES/CEDAR BAY COGENERATION PROJECT
                       . NPDES Permit No.  FL0041173
                       FEBRUARY 6 - MARCH 18, 1992

         ?*'  AES conme»ced construction under a different
                                                                 the

                                                            completed

EPA Response;  see  response A. 3.
                                                             Pnntea on

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1
                        I          -2-
  Comment g.i  Construction continues even though the Mavor of

  certification    requested suspension of AES/Cedar Bay's site
   crtificatin


   EPA Response t   See response A.I.
                                             •

   Comment g.t  The issuance of an NPDES permit for storm water

   discharges during construction, while there remains unresolved
   issues, may add to the instability of this situation?


       *e!?onse8  EPA has investigated the possible impacts to the
  ••
      Jacksonville, PL 32202-4111,  March 11,  1992.

  Comment: Slides of the AES site are  submitted for EPA review.
  EPA Response?  EPA
  concerns regarding
  water discharge due to metais and phenolic compounds by
  monitoring of these pollutants in the final permit,  if
  monitoring data indicates that water cualitv stanrtavrie «ZlT~w~.j
  v{rtia*a<4  4-v^ ___*.•.  i*<,  "•"*•• »»»»•«*. yuaxity Etanaaras are beino

  pouSt^."! n^r111 *•reopened to incii'de ij»its *»
  c.
                        ss-s

                                          _waterermit will be
 .automatically become invalid upon commencement orlfiFations



 Comment 2.;  Issuance of a storm water permit for

 SSS^Si0!? ±?*S na2°r TSderal acti°n ^^ wnf
 environment!16     *** V*lfm °£ the  citizens' wildlie, a   the
PPA Response:   EPA feels the conditions in the storm
                                                     water

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                                  -3-
  discharges.  The final permit contains site specific permit
  conditions to insure that the effluent does not have an adverse
  impact on the receiving waterbodies.

  It should be noted that on November 13, 1991, PDER waived
  certification of the proposed NPDES permit under Section 401 of the
  Clean Water Act.  The effluent limitations in the final permit are
  at least as stringent as those specified in' the State's permit for
  this facility.  The waiver was based on two changes that EPA has
  incorporated into the permit.  The final permit contains additional
 monitoring requirements for metals and phenolic compounds,  which
 were not contained in the draft permit, thus making it more
  stringent.  Since several changes were made to the draft permit
 since the November 13, 1991 waiver, FDER reaffirmed its waiver of
 certification by letter dated July 22, 1992.

 Comment 3.»   If EPA elects to issue the construction storm  water
 discharge permit without the benefit of an EIS,  then EPA should
 tighten the  discharge limits in the draft permit,  require
 additional monitoring, and regulate the emergency discharge to the
 Broward and  St.  Johns Rivers.          .                  *

 EPA Response:   Comment noted.   The final  permit  contains  monitoring
 requirements that were not included in the draft permit.  In short,
 in addition to  the parameters  in the draft permit,  the  final permit
 requires  the permittee to  monitor Outfalls 003 and 008  for  12 more
 pollutants --- nine metals and three phenolic compounds.  Also,
 during emergency discharge periods to the  Broward  River,  the final
 permit requires  that  an additional 20 parameters be monitored.

 Comment 4.;  The site  is highly contaminated with petroleum-based
 fi™???™^?  ,^n*enSi?r ?f construction activities at the  site has
 significantly disturbed these contaminants  and could, in  turn,
 contaminate the  Broward and St.  Johns  Rivers.

 EPA Response i  According to AES,  the petrolenm-ba^ri. contaminated
             re  1?"ted S" ^eir Property.  The only contaminated
             was lune mud, which  had previously been deposited bv
                                                  is contaminated
all^h^^V1?6/"1^ rePresentatives from AES have stated that
all the contaminated mud lime on site was removed and replaced with
«: an*"1"1-  (2?e J1*6 nud W" *oved to an «l?erSadiv?J?orfge
con«i-^d«- V5r° d£?char9e evaporation/percolation pond was
~?!«f?   d £2r t?is area'>  ^y storm water discharged from the
retention ponds should not be contaminated by residull lime mud?
                  tvAES has stated that construction activities
                  *?* contaminated groundwater.  The contaminated
           « iBSues,have bfe« addressed in the Conditions of State
    e clrti??ra?d in the.finalvN*DES permit.   The Conditions of
   conSn^H   5 °n re(Juir^s that a groundwater monitoring program
   conducted and,  as stated in EPA's response to comment 1.3, th™

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                                  -4-

  f inal NPDES permit requires additional monitoring to detect certain
  metals and phenolic compounds that may possibly be present in the
  discharges from the retention ponds on site.  Additionally, the
  NPDES permit contains a provision for AES to develop and implement
  an Erosion and Sedimentation 'Control Plan.  The plan requires
  several conditions to ensure that contaminated (and
  non-contaminated) soil will not cause degradation of surface waters
  during rainfall events.  Site grading and drainage were designed
  and completed in accordance with all applicable Federal, State, and
  local regulations.


 Comment g.»   Issuance of an NPDES permit for storm water discharges
 during construction could be misconstrued by AES,  leading the
 company to believe that EPA will eventually approve the AES/Cedar
 Bay Project.


 EPA Response » AES is fully aware that the issuance of a NPDES
 permit for storm water discharges during construction does not
 assure EPA approval of the project.


 Comment 6.;  Issuance should be  held up  until;  (1)  the EIS is
 complete,  (2) all modification to the Conditions of Certification
 are  finalized,  (3)  the Governor  and  Cabinet  decide  whether to
 suspend or revoke the Conditions of  Certification.

 EPA  Response; Comment noted.  See response to comment A.I.


 D.  Mr. Greg Radlinski, City of  Jacksonville, Office of  General

    £archeii 6lty Hal1'  22°  EaSt Bay Street' Jacksonville, FL,
Comment l.t  The City of Jacksonville disagrees with EPA's decision
to issue separate NPDES permits for construction storm water runoff
and process water discharges.

EPA Response; Comment noted.  See response to comment C.l.


Comment 2.t  The Council disagrees with EPA's conclusion that the
construction storm water discharge is not a major Federal action,
significantly affecting the quality of the human environment, and
therefore, outside the EIS process.
        ^
EPA RespcmRp*  Comment noted.  See response to comment C.2.


Comment 3.;  EPA should reconsider the issuance of a storm water
permit without an EIS.

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                                  -5-

 EPA Response;  The discharge resulting from the construction
 activity does not require that an EIS be performed (i.e.  the
 issuance of the storm water permit is not related to the  NEPA
 process).

 Comment 4 . t  If a storm water permit is issued without completion
 of an EIS, the City requests EPA tighten the proposed discharge
 limits, require additional monitoring, and regulate the emergency
 discharge to the Broward River.

 EPA Response; Comment noted.  See response to comment C.3.


 Comment 5 . ;  The soil and groundwater at the site are contaminated
 and storm water from the site would contaminate the Broward  and St.
 Johns Rivers.

 EPA Response;  See response to comments C.3 and C.4.    :


 Comment 6.1  The Jacksonville City Council has frequently expressed
 its opposition to the AES/Cedar Bay Project.

 EPA Response:  See response to comment A.I.


 E.   Mr.  Grady Marchman,  Water Quality Division,  Jacksonville
     Regulatory and Environmental Services  Department, March 11,
Comment  1 . t  The AES/Cedar Bay Project is being constructed on a
contaminated site and the pollutants on the site can reasonably be
expected to be contained in the construction related runoff.  The
monitoring proposed in the draft NPDES permit is inadequate to
detect the known contaminants.

PPA Response; Comment noted.  See responses to comments C.3 and
C • 4 •



Comment  2 . t  EPA should require all volumes of storm water
transferred to the St. Johns River outfall be reported, since AES
can readily report by means of their pump logs.
                                         *
EPA Response s The permit requires monitoring of storm water flow
rate at Outfalls 003 and 008, which are combined prior to discharge
from Outfall 001, which discharges to the St. Johns River.

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                                  -6-

 Comment 3.t  In addition to the once per week monitoring
 requirements for flow and total suspended solids  at  Outfall  001,
 the following pollutants should be sampled upon any  discharge of
 storm water from Outfalls 003 and 008 to Outfall  001s

     Full Time Flow (by pump logs), Copper, Zinc,  Mercury, Arsenic,
     Antimony, Beryllium, Cadmium, Lead,  Nickel, Phenol,
     Naphthalene, and Toluene               •           .     .


 EPA Response!  Monitoring requirements for these  pollutants  have
 been included into the final permit.


 Comment 4.8   The following pollutants should be monitored at
 Outfall 001t

     Zinc,  Mercury, Arsenic, Antimony, Beryllium,  Cadmium, Lead,
     Nickel,  Phenol, Naphthalene, and Toluene

 PPA Response:  Through an agreement between Seminole Kraft and
 AES/Cedar  Bay,  effluent from the two retention  ponds on  site
 (Outfalls  003 & 008) will be allowed to  be discharged  from Outfall
 001.  The  effluent quality from Outfall  001 is  presently permitted
 (NPDES permit no.  FL0000400) and is being monitored  by Seminole
 Kraft Corporation, the owner of the pipe at this  discharge point.


 Comment JL«.t   There is an emergency discharge from the  storm  water
 ponds directly to  the Broward River.   This point  has not been given
 a  point source  designation number,  even  though  this  is a
 channelized  conveyance of storm water runoff that discharges from
 lands used for  industrial activities.  The City proposes monitoring
 requirements for the following list of pollutants!

             Biochemical Oxygen Demand, Total Organic Carbon,
             Turbidity,  Dissolved Oxygen,  Total Kjeldahl
             Nitrogen,  Phosphorus,  Oil  &  Grease, Copper,
             Arsenic,  Zinc,  Mercury, Antimony, Beryllium, Cadmium,
             Chromium, Lead,  Nickel, Phenol,  Naphthalene, and
             Toluene

EPA  Responset Comment noted.   See response to comment £.3.
F.  Mr. Steve Wolf, AES/Cedar Bay, March 11, 1992.

Comment }.t  The storm water discharge permit was addressed in the
overall power plant siting process.  AES feels that the permit and
the monitoring, as certified, were appropriate and typical for
storm water discharges.

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                                -7-

  EPA Response; Comment noted.


  Comment ?T>  Any particular monitoring of the surface water
  discharges, in efforts to detect a possible migration of
  contaminated groundwater contained in the site _ certification,
                        bein9
                                          ?a esrs s.

 EPA Response*  Comment noted.




 JPA Response t Comment noted.
G-
PPA ResponsPi Comment noted.   See response to comment A. 6.
                          ^

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                                  -8-
  Coinment 3t>   Before considering another environmental permit under
  the KEPA process,  EPA should go back and review the earlier
XUH??1?1 °f Si9nif}cant Deterioration (PSD)  determinations.   The
Council has reservations about its propriety.


EPA Reenone^t See response to comment A. 3.


                                           •

             Until nodfficati°*s to the State's conditions of

                  v??lied for'  found sufficient, and after
                   v                            ,

 HI 2 ™ L S^?^liC re7lew accepted' ifc 6eeas unconscionable for
 AES to go on building under the presumption that all the charges
 they want, and are asking for are certain to be approved.


 EPA Response : See response to comment A. 3.



 Comment 5T«  Any permit that might be used as a justification to
 continue construction would be a mistake.          »t«ic«xon to
 d«oh         ,Issuance of t*e NPDES permit for storm water
 project?   durin& construction does  not assure  EPA approval of the
              SSFJ*?? Stat?'S  fPecial council concludes its review
                  City's claim of misrepresentation during the site

                r°Cedin9,'  and until the Governor and Cabinet decide
                 suspension or revocation, no permit that might be

                     1^              ^ency Approval shoull be*"
 EPA ResponsP: Comment noted.  See response to comments A.3 and C.5



 H.   Hs. Barbara Broward, Citizens Committee, Inc.


 C°™ent it  AES continues to build despite the fact that the

 SSen £ "aiSed?0     State'S Conditions of Certification havl not


 EPA Response t Comment noted.  See response to comment A.'l.



 f^e"^2;!  Contamination in the soil at. the site tend to shift
 into the digging areas.  This leaves holes and vacancies in the

5a£h an4 KP°S Sibly allowin9 ^ese contaminants logel Into the
water or by heavy rains.  Allowing discharge of an? harmful

                            W°Uld be addin9 to an ^reSSy existing
EPA ResponsPt Comment noted.  See response to comment C.4.

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 Comment 3. i  The permitting process should be halted until
 unresolved issues are adequately addressed.

 EPA Responset See response to.comment A.6.


 Z.  Dot Mathias, Northside Civic Association, March 11,  19912.
                                            t
                                                       • •
 Comment 1.t EPA should deny storm water permit.

 EPA Response; We have no basis to deny a permit  for storm water
 runoff during construction.  Our permit should ensure that Class
 III water quality standards are met.


 Comment 2.:  AES is being allowed to build over  a contaminated
 site.

 EPA Responset Comment noted.  See responses to comments  C.3 and
 C.4.
                                       •

 Comment 3.t   AES has covered the contaminated soil with  tons of
 sand.
 EPA Response!  Comment noted. See response to comment C.4.


 J.   Andy Johnson,  March 11,  1992.

 Comment 1.t   There are,  and have been, storm water discharges  from
 the retention ponds.

 EPA Responses  No documentation was submitted to  substantiate this
 claim.   EPA conducted a  site investigation and found  no evidence
 that  suggested a discharge  from  either pond had  occurred.


 Comment 2.s  The claim by AES that groundwater could  not get into
 the storm water  retention ponds  is untrue.  EPA  should investigate.

EPA Response; EPA  has  investigated the possibility of storm water
contamination by groundwater and feels that AES has taken adequate
measures to prevent groundwater  from migrating into the retention
ponds by constructing  the ponds  on ground that is above the water
table.  Additionally,  the water  in the aquifer should not migrate
into the ponds because the aquifer at the.site is not under
hydrostatic pressure.  For assurance, the final permit requires
additional monitoring; see response to comment C.3.

-------
                                 -10-

 K.   Richard Stockstill,  Pt. George Island, March 11, 1992.

 Comment 1.i   If  a storm  water discharge permit is issued, there is
 enough material  involving the AES project for a class action suit
 to be filed.

 EPA  Response: Comment noted.
                                           t


 Comment 2.:  EPA should  investigate the alleged contamination at
 the  AES site by  reviewing the testimony of the Florida hearing
 officer,  which was given in February of 1990.

 EPA  Response!  Comment noted.



 L.   Mr.  Owen Williams, AES/Cedar Bay, Inc., March 11, 1992.

 Comment t  AES has removed all the lime mud from the site..
 Contaminated groundwater cannot get into the storm water retention
 ponds.

 EPA  Responses Comment noted.

 M.   Dr.  Robert Haines, 3342 Environment Road, Green Cove Springs.
     FL, March 11,  1992.

 Comment  ;.;  There will  be prima facie evidence in the future that,
 unless  the water risk assessment is done, there will be negligence
 on the  part of the agency for not incorporating that in the risk
 assessment.


 EPA  Responset Comment noted.



 Comment 2.s  The potential of rivers becoming contaminated by heavy
metals should be addressed.

 EPA Response; Comment noted.  See response to comment C.3.



N.  Ms. Leslie Billingham, 36444 Hendricks St., March 11, 1992.

Comment»  There exists on-site contamination  that has not been
cleaned-up and it could affect .the quality of the storm water
runoff.

EPA Responsei Comment noted.  See response to comment C.4.
                                  H-7o

-------
                                  -11-
  O.   Mr.  Harry Reagan, Councilman, Office of the  City Council,
      220  E. Bay Street, Jacksonville, Florida  32202, March 16,
  Comment la The Jacksonville City Council has repeatedly expressed
  its opposition to this co-generation project.  However, ^ES has
  been building its plant without having received all appropriate
  permits, including the construction storm water discharge permit.
 f!^??!*0?!!'  E*A has no authority to prohibit construction of a
 facility and no point source discharge from the AES site has
 occurred.
 £S!!?nT ?*' TI?? Governor directed the Attorney General to appoint a
 special investigator to investigate AES.  The City called for
 reopening the site certification, with the possibility of
 suspending certification of the project.
 JI^BesEonsei   Comment noted.  EPA is aware of the May 5,  1992,
 aeeting in which FDER was directed to undertake proceedings for
 revocation or  suspension of AES' s site certification.
               fDER and AES fntered int° discussions concerning the
             «*!! * result of these discussions, FDER issued a
        Board Order initiating modification of the site

                                                B July 7'  1991'
                                    * council voted to '
EPA Respons**.   Comment noted.


P'
    f;^UfUS Pe^n5t°n' «I» Margol and Pennington, P.A.,
    Attorneys at Law, Suite 1702 American Heritage Tower/76 South
    S^'SS' FL  32202' March  15' »«•  cSS
                                                        n
representatives of the City of Jacksonville at theMarlS ll?  9 9 2

            We   a8 a11 °f the °ther coranents receive? at the    '
EPA Respnncot   Comment noted.
                                   U-ll

-------
                                  -12-

     Robert G.
                                         Environmental Consulting
                                         Park'  FL  32067-0733,
         *' Polluta*ts are not adequately defined by the applicant











          '  No risk assessment has been done for pollutants in
                                                           —
  devastating effect on the ecys tern      ' W   utlmately causa

PPA ResponRPt  Comment noted.   See response to comment C.3.




               Crament noted.   This concern was not directlv
                     eCl """   ^t

              See response to comment Q.4.

                                 \\--J2.

-------
                                 -13-

 EPA Responses   See  response to comments D.3.


 Comment ?.«  New evidence of adverse effects to mammalian tissues
 from ceratin heavy  metals was presented at the recent Toxicoloov
 meetings.                                                     aJ

 EPA Responsei  Comment noted.              •            :

 Comment p.t  The Agency, by allowing the NPDES permits, "is
 establishing a posture of direct co-liability for pollution damages
 5£f1WeaVVttttai8 whf?h wil1 k® ln the daily effluent, according to
 the City of Jacksonville's  evaluation of the proposed discharge
 into the Broward and St. Johns Rivers.  Recent legal precedence of
 Government liability in tort in Jacksonville clearly has bee£ let
 *£.«—*«*  Ufe*«as Judicial notice in any future civil action
 against AES and EPA.  Causation would be easy to prove, since
ha"™  aJSe«SL?SaVyvJnetal8 W0uld ** slffiPle to monitor.  None would
have  any growth enhancement or therapeutic value, and it could not
be argued that these elements would not be adverse on an
?,f™?iatiV? bases 5° 5he rlver ecosystem.  At least the Agency is
5£2£J?    ? ?arned that issuin9 *n NPDES permit without 1   *
fiunno^*"7 risk assessment is scientifically invalid.  The Agency
          in mind that the reason why FDER,  and now the Attorney
          Office is  reviewing the State Certification many months
          racr,  as that false and misleading information appears --
          provided by the »—~i*——*-    -  	.     -       rr-
                                                           s  gross


             T5e  f inal Permit  has  language, that allows EPA to
                     include « effluent  limitation, or othe?
                     ffiOnito*ii9 data indicates a waier quality

-------

-------
                                                       MASS BALANCE
Attendant 1
021089
Aatndvtnc 2
070719
Aaendacnc 5
H-73

-------
i










t
„. 	 ^^^ 	 l^*-^«^^«^^/^i; | fssSmtM
2D 1 ** enA New Sourcef ind New Dischargers
*JJi 1 <>cRAAppllicationforPerm^
Nr MCA •Wrf*«. Ml tfW IMNW* V
OvfW NwmMT
flMr;
001
002
003
004
005
006
UMMtf
f^H ^LA
•^^^ ^^^n
30 24






in FI*M. t,_ iu •« fiijuir
»
S*c
55





«l«n«
* L
0^
81





>tud«.
•n««u
MM
35





•nMih
M
S«e
45





i n««M e( it* f «c*»vtnt «Mtw
SMM, «•«.*» /
bciatiag outfall la tha St. Johaa Rivar
Monitoring poiat for cooling tovar blovdovn
Moaitoriag point for runoff ratantion baain
Monitoring poiat for boiler blovdovn
MonltorinR point for construction dcvatcring
HonitoriJlf flint for low vgi<«* «••»••


TfMV*
•Nt Tl
NftMt
•*M I
A. For aach outfall, provrta a daacr iption of ( 1 J All oj
procau waatawataf. aanrtary wattawatar, eoo
-------
CO*t '/ I OwtUn Muma* 1
1 	 | nonl tori tic 'oltit 005 1
A. and B These items require you to repon estimated amounts (bet ft concintrftion tndmissjtf the pollutants to
be discharged from each of your outfalls. Each part of this itam addresses a different set of pollutants and should
t completed in accordance with the specific instructions for that pan. Data for aach outfall should be on a
operate page. Attach additional sheets of paper if necessary.
General Instructions /"See laeVe 2D-2 /or Polluttntt)
Each pan of this item requests you to provide an estimated daily maximum and average for cenam pollutants and
the source of information. Data for all pollutants in Group A, for all outfalls, must be submitted unless waived by
the permitting authority. For all outfalls, data lor pollutants in Group 8 ahould be reponed only for pollutants
which you believe will be present or ara limited directly by an effluent limitations guideline or NSPS or indirectly
through limitations on an indicator pollutant. .
I.NMWIWM
10D5
COD
TOC
TSS
Ammonia
Teaperature (Winter)
Teaperature (Suaaer)

Flow '
Citrate (as K)
Phosphorous (as P)
Sulfatt





Lead
M.rrurv
Nickel
leniun

fnrfm* unurjj
27 mg/l
295 kc
143 mg/l
1.560 kc
5 mg/l
55 kc .
753 kc
0.68 mg/l
7.4 kc
90 F
90 F
12.0
2.880,000^
1.8 mg/l
20 kc
0.7 mg/l
7.6 kc
1.636 kc
2.0 mg/l
21.8 kc
165 mg/1
1.800 k.
5.7 mg/l
62.1 k.
<0.16 mg/l
<1.74 mg/l
<13.2 kc
<0.0022ag/l
<1.57 kc
<0.017 ag/1
<0.18 kc
<6.4 ag/1
'H**
14 mg/l
90 kc
73 mg/l
464 kc
3 mg/l
19 kc
40 mg/l
254 kc
0.34 mg/l
2.2 kc
60 F
80 F
8.0
1,680,000^
0.93 ttg/1
6 kc
0.5 mg/l
5.4 kc
100 mg/l
635 kc
1.8 mg/l
19.6 kc
110 mg/l
700 k.
5.1 mg/l
32.4 k.
<0.13 mg/l
<0.8? k.
<0.94 mg/l
<1.0 mg/l
<6 36 kf
<0.0018c|,
<0.119 mg/
<0.76 kc
<0.011 BR/,
<0.07 ke
<4.4 mg/1
A|HN.|H..mMM
4
4
4
4
A
4
4
4
4
A

4





4



k -71
Cadmium
<0.010 mg/l
      ke
<0.009 mg/l
<0.06 kc    4

-------
                                                            Monitoring Point  005
                    MIT If  .  ItDUSTIlAl lASTCIATtt CNAIACTCIIST1CS
l«f.r..ti.« furnish.* m tliit • •etUn  f»r et«.truetl.« M»a  ttiall  »• ••••«
                "* •••* •r»f«"»«»»»» j»«««tfit.
        ..1:; ::;:-fr.::;-i:;at:'t'1  If
   n».
                                                                               r..,0n-
                                         2.88
           2.88
§.  ««ttr Quality Chtracttriatiia «r Crnw«nt
          MIAMCTCI
                                                                  '  2.88
             «r

    »«st/n*wtrcl tttreettfel*

    •ci« ••trtettiUi

    t«t«l «r«anie carMn  (IOC)

                            (MO)
          •ttcit
    •»«clfie

    ttapcratwr*

              ••!!«•
OCR r.r« 17.1.204(2)
 rrtcti»* n*vt»ktr  so,  1*12
                                                                        unit*)
HlAlBWB






Stc 10.1.1
6.0

60 F







HtllVWB



5 ttg/1
27 ag/1
Ste 10.1.1
NPDES
Application
N?DES Applica
12.0

SO F
•
69 ag/1










3 ag/1
1* »g/l .

:ion
8.0

80 F Summer
60 T Vlnrvr
40 Bg/1






                                   Page 5D of 9

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      CEDAR BAY COGENERATION PROJECT
SITE STORMWATER MANAGEMENT PLAN DESCRIPTION
            BECHTEL CORPORATION





              GAITHERSBURG, MD





                MARCH, 1993

-------

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                       TABLE OF CONTENTS





                                                       Page No.








I.         INTRODUCTION                                        1





II.         SITE .DESCRIPTION                                     2





III.        BASIC DATA                                          3





IV.        RUNOFF ANALYSIS        .                             5





V.        STORMWATER MANAGEMENT RUNOFF ANALYSIS RESULTS      6





VI.        SURFACE WATER HYDROLOGY                            8





VII.        EXTREME RAINFALL FOR THE AREA                        9





VIII.       CONTAINMENT OF STORAGE AREA RUNOFF                 10





IX.        ASSESSMENT OF EXTREME PRECIPITATION'EVENTS           11





X.        CONCLUSIONS                                       12





XI.        REFERENCES                                         13

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                         LIST OF TABLES
TABLE-1    STORAGE AREA RUNOFF POND (SARP) STAGE-STORAGE

TABLE-2    YARD AREA RUNOFF POND (YARP) STAGE-STORAGE

TABLE-3    SUMMARY OF RUNOFF ANALYSIS AND STORAGE AREA RUNOFF
          POND (SARP) WATER LEVEL DURING PLANT OPERATION

TABLE-4    SUMMARY OF RUNOFF ANALYSIS AND YARD AREA RUNOFF POND
          (YARP) WATER LEVEL DURING PLANT OPERATION

TABLE-5    SUMMARY OF RUNOFF ANALYSIS AND SARP WATER LEVEL DURING
          PLANT SHUTDOWN

TABLE-6    SUMMARY OF RUNOFF ANALYSIS AND YARP WATER LEVEL DURING
          PLANT SHUTDOWN

TABLE-7    SUMMARY OF St. JOHNS RIVER FLOW AT JACKSONVILLE, FLORIDA,
          DAILY FLOW VOLUME

TABLE-8    FLOW  STATISTICS  FOR St.  JOHNS  RIVER  AT JACKSONVILLE,
          FLORIDA
TABLE-9    PRECIPITATION AT JACKSONVILLE, FLORIDA
                        LIST OF FIGURES
FIGURE-1   CEDAR BAY PROJECT LOCATION AND VICINITY MAP
FIGURE-2   SITE PLAN

-------
                    CEDAR BAY COGENERATION PROJECT
           SITE STORMWATER MANAGEMENT PLAN DESCRIPTION
       INTRODUCTION
 This document provides a description of the stormwater management plan for Cedar Bay
 Cogeneration facility site.  The overall goal of the plan is to capture and retain site stormwater
 runoff for use as cooling tower makeup water. The information provided includes a description
 of the plan modifications that have been made from earlier submittals. These modifications
 further enhance the facility's ability to maximize water  reuse and minimize  potential  for
 discharge during extreme rainfall events.

 The primary differences between  the proposed plan and  information provided in previous
 submittals is the addition of an emergency water storage tank and an increase in pumping
 capacity from the site storage area runoff pond (SARP).

Stormwater will be pumped at an increased capacity from the SARP either directly to the zero
discharge  facility for treatment prior to reuse in the plant or to the emergency water storage
tank.
                                           H-?3

-------
 H.    SITE DESCRIPTION
 The Cedar Bay plant is located on leased land adjacent to the existing Seminole Kraft (SK)
 recycle mill.  The SK mill site is  situated along  the Broward  River, approximately 3/4 mile
 upstream of its junction with the St. Johns River. The portion of the existing SK site being
 leased for development of the Cedar Bay Cogeneration Facility was used by SK as a storage area
 for lime mud and waste byproducts prior to conversion to recycling operations; it also contained
 a rail yard and lime settling ponds (see Figure 1).

 Initial site preparation for the Cedar Bay project involved the relocation of accumulated lime
 mud to a storage area in  the northwestern portion of SK property.   Clean  granular fill was
 placed and compacted on the cogeneration facility site subsequent to removal of the lime mud.
                                            •
 The site layout plan for the cogeneration plant is shown on Figure 2.  The plant will burn coal
 in a fluidized bed boiler, and use a  cooling tower for heat rejection. Coal will be delivered to
 the site by rail, and stored in the Coal Storage Area.  Ash will be stored in silos, or pelletized
 and temporarily stockpiled on-site.  Pelletized ash will be conveyed back to the coal mine, by
 rail, for ultimate disposal.

 The plant has been designed as a zero discharge facility; plant wastewater (including cooling
 tower blowdown, coal, limestone and ash pellet  storage area  stormwater runoff, yard  area
 stormwater runoff, and low volume plant  wastes such, as boiler blowdown, floor drains, and
 demineralizer regeneration  wastes) will be treated and reused in the cooling tower.

 Existing site runoff is directed toward the Broward River. The stormwater management  plan
 makes use of the existing drainage  pattern.  As shown on Figure 2, a stormwater collection
 network will direct runoff from the  facility area to one of two stormwater management ponds.
 Stormwater runoff from coal, limestone and  ash  pellet areas will be conveyed to the lined
 storage area runoff pond (SARP). Runoff from the power block will be collected in the yard
area runoff pond (YARP).  Water collected in both ponds will be used for plant cooling.

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  BASIC DATA
  The storm water runoff from the Cedar Bay Cogeneration Project Facility (Figure 2) is
  conveyed to two on-site runoff ponds. Water from these ponds is pumped to an on-site
  zero discharge plant and reused in the plant.  The SARP is a lined pond.

  An emergency water storage tank with one million gallons (3.07 acre-ft) capacity is
  provided to store water pumped from SARP during plant shutdown.

  The pump at the YARP is rated at 500 gpm and its operation is based on pond water
  level.  Pumping starts when the pond water level reaches an Hev.  of 9 ft National
  Geodetic Vertical Datum (NGVD) and trips when the water level drops to an Hev  of
  8 ft NGVD.

 The existing  pump at the SARP is  rated at 500 gpm and its operation is based on the
 pond water level. Pumping starts when pond water level reaches Elev. 9 ft NGVD and
 trips when water level drops to Hev. 8 ft NGVD.  In order to eliminate the overflow
 from this pond to the river, a sensitivity study was conducted with pumping capacities
 ofTOOgpm, 1,000 gpm and 1,200 gpm. Based on this assessment, the pumping capacity
 from the SARP will be increased to 1,200 gpm.

 The crest of the spillways for both ponds are at Bev. 12 ft. NGVD.  The SARP and
 YARP volumes to spillway crest  arc 7.15 acre-ft and 7.57 acre-ft respectively.  With
 bottom storage between H. 7 ft and EL 8 ft NGVD reserved for siltation, the net runoff
 volume which can be stored in the SARP is 5.86 acre-ft and YARP is 6.40 acre-ft. The
 pond stage-storage details are shown on Table-1 and Table-2. The combined net storage
 volume of the SARP and emergency water storage tank is 8.93 acre-ft.

The overflow from the pond's spillway to the river is conveyed via a combined discharge
chute.

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 •     Contributory drainage areas to these ponds including pond areas are:

             Storage Area Runoff Pond (SARP)                    10.9 acres

             Yard Area Runoff Pond (YARP)                      12.6 acres

       YARP contributory area includes an area  of 0.8 acres occupied by  zero discharge
       wastewater  treatment facility and excludes  an area of 0.5 acres occupied by cooling
       tower. The runoff from the cooling tower is conveyed to cooling tower basin and does
       not contribute to runoff conveyed to YARP.

 •     SARP contributory drainage  area includes a 2.4 acre coal  storage area, a 0.37 acre
       limestone storage area, and a 0.36 acre pelletized ash storage area.
                                           •
 •     The 24-hour duration rainfall frequencies considered for this assessment are 10-, 25- and
       50- Year events.

 •     The rainfall  data as per SJRWMD District Technical Publication SJ 88-3 (Ref. 1) are:

             10-year, 24-hour          7.46 inches
             25-year, 24-hour          9.34 inches
             50-year, 24-hour          10.8 inches

•     The weighted Soil Conservation Service (SCS) runoff curve number (CN) used for runoff
      analysis is 85.

•     The Broward River near the site is classified as Class m marine water.

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 IV.   RUNOFF ANALYSIS
The runoff analysis was performed based on SCS methodology, using a runoff curve number,
time of concentration, and total rainfall.  The runoff analysis and routing of the flow through
the yard area and the storage area runoff ponds was performed using the U.S. Army Corps of
Engineers HEC-1 Flood Hydrograph Package (Reference 2). The analysis incorporates pumping
from the coal pile area sump to SARP.

The analysis was performed for the 10-, 25- and 50-year, 24-hour storm events.  Peak water
levels within the runoff ponds are determined from the HEC-1 program routing  model with
pumping  from each runoff pond to the plant zero discharge facility.  Based on the analysis, a
runoff depth for each subarea  was calculated and a total runoff volume to the pond  was
determined. This volume is compared to the total runoff pond volume along with the emergency
water storage tank volume to determine if overflow from the runoff pond will occur in the event
of a plant shutdown.  The results of the analysis are shown in Tables 3 through 6.

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 V.    STORMWATER MANAGEMENT RUNOFF ANALYSIS RESULTS
 Plant Operation Condition

 •     Stormwater runoff from the SARP and YARP will be pumped to the onsite zero
       discharge facility and reused in the plant.

       Table-3 summarizes stormwater runoff, maximum pond water level and peak overflow
       rate for the SARP with various assumed pumping rates and storm frequencies.  Based
       on this analysis, a pump at the SARP, with a capacity of 1200 gpm, will eliminate any
       overflow to the river for the 10 year, 25 year and 50 year, 24 hour storm event.

       Table-4 summarizes the requests of the analysis for the YARP.  As indicated, there is
       no overflow from the YARP during the 10 year storm. During the 25 year and 50 year,
       24 hour storms,  the peak  overflow rates are 0.3 cfs and  3cfs, respectively.  The
       corresponding overflow volumes for the 25 and 50 year, 24 hour storms are 9105 cubic
       ft and 67,975 cubic ft, respectively. This overflow lasts for 5 hours during a 25 year
       event and 13 hours during a 50 year event.

Plant (Turbine Generator) Shutdown Condition

When the turbine generator is not in operation, stormwater cannot be utilized in the plant for
cooling purposes.

Under this condition, the following  observations can be made:

•     No overflow will occur from either runoff pond during the 10-year, 24-hour storm event.

•     During larger storm events, the water from the SARP will be pumped to the emergency
      water storage tank, stored and reused in the plant.  This will result in no overflow from
      SARP to the Broward River for extreme, rainfall events up to 50-year 24-hour storms.
      The volume pumped (Table-5) is less than the capacity of the emergency water storage
      tank.

-------
 The SARP can store runoff generated by up to 8 inches of rainfall without any overflow
 during plant shutdown condition. Thus, with the use of the emergency water storage
 tank, the combined capacity of SARP and tank is equivalent to about 9.83 inches of
 runoff generated by 11.5 inches of rainfall. This rainfall corresponds to a 24-hour storm
 frequency of about 70 years.  The summary of stormwater runoff and minimum runoff
 volume to be stored in the emergency water storage tank,  during the operation of SARP
 pump with pond water level at spillway crest, is shown on Table-5.

 During a 25-year, 24-hour event,  there will be an overflow of 64,900 cubic feet of water
 from the YARP to the Broward River. The peak overflow rate and overflow volume to
 the river from YARP is shown on Table-6.

The YARP can store runoff generated by up to 8 inches of rainfall without any overflow
during plant shutdown condition.  This event has an approximate frequency of 13 years.
Thus this event would occur approximately 2 times in the life of the plant.

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 VI.    SURFACE WATER HYDROLOGY

 The Cedar Bay project site (Figure 1) is located within the estuarine portion of the St. Johns
 River Basin, about 13 miles upstream of the mouth of the river.  The surfece- waters in this
 vicinity have been classified as Class m, predominantly marine waters, in Chapter 17-3 of the
 Florida Administrative Code (FAC).  Waters of this type are intended for fish and wildlife
 propagation and management.  Water test data show the presence of salt water in the St. Johns
 River adjacent to the proposed site.

 The plant site located on the Broward River (Figure-1), is less than one mile upstream of its
 junction with the St. Johns River. The Broward River in this reach is tidal and affected by flows
 and stages of the St. Johns River.
                                             •
 The nearest stream flow gaging station on the St. Johns River, approximately 25 miles upstream
 of the mouth of the river, and about 12 miles upstream of the site area, is maintained by the
 USGS. There are no other published records of stage and/or flow in  the site vicinity.  The
 stream  flow data for the St. Johns River at Jacksonville, Florida (Station 02-2465) over the
 period 1954-1970, shows that the flow at this location  is affected by tides.  Variation in the
 ocean level increases or decreases stream flow for the St. John's River,  by causing changes in
 basin storage.  The published flood and ebb tide volumes in USGS Water Supply Papers (Ref.
 3) at this station are summarized in Table-7.

The flow statistics for the St. Johns River at Jacksonville, based on the records  computed for
the March 1, 1954 to September 30,1966 (Ref. 4) arc shown on Table-8. Based on above data
the minimum daily downstream flow volume for St Johns River is 540x10* cubic feet (Table-7).
The average  net flow in the river is 5,883 cfs. Maximum daily net flow in the river is 87,000
cfs (Table-8).
                                         8

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 VH.   EXTREME RAINFALL FOR THE AREA
 The rainfall analysis for Northeast-Florida was performed  by the  St Johns River Water
 Management District (Ref. 1, 5 & 6). These studies include an analysis of historic data and
 development of rainfall frequency curves.  Based on the historic data for the Jacksonville Airport
 for the period of 1867-1984 (98 years), the monthly average,  minimum and  maximum
 precipitation (Ref. 6, Technical Publication SJ 86-4) is shown on Table-9.  The mean monthly
 precipitation for the wettest month of September is 7.29 inches. The corresponding maximum
 monthly precipitation of 15.80 inches occurred in year 1947 in the month of September. The
 mean annual precipitation is 51.73 inches, with an observed minimum annual of 32.56 inches
and maximum  annual of 82.27 inches. The design basis rainfall values derived by SJWMD
reflect these extreme rainfall events.

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Vm.  CONTAINMENT OF STORAGE AREA RUNOFF
The storage area runoff volumes for the 10-, 25- and 50-year 24-hour storm events which need
to be contained are as follows:
FREQUENCY, YEARS
10-YEAR
25-YEAR
50-YEAR
RUNOFF VOLUME, acre-ft
5.17
6.82
8.08
•
With a total combined storage volume 8.93 acre-ft for the storage area runoff pond, along with
the volume of the emergency water storage tank, no overflow from the SARP will occur up to
the 50-year 24-hour storm event.
                                       10

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 K.   ASSESSMENT OF EXTREME PRECIPITATION EVENTS
 •     The major on-site areas affecting runoff water quality are the coal storage area, lime-
       stone storage area and cured-ash-pellet storage area.  The coal storage area runoff and
       the limestone storage area runoff are pumped to the lined SARP.  The cured-ash-pellet
       storage area runoff flows directly to the SARP.  All runoff collected is reused in the
       plant, or stored in the emergency water storage tank and then reused.

 •     The suspended solids conveyed by runoff will  settle in runoff ponds.

 •     No overflow to the river from either pond will occur during the 10-year 24-hour storm
       event, with the plant in operation or shutdown.

 •     With a pumping  capacity of 1,200 gpm along with the use  of the emergency water
       storage tank, no overflow from the SARP to the river will occur during 25-year and 50-
       year 24-hour storms.  This is true both for operational  and shutdown conditions.

 •     For extreme events higher than  10-year 24-hour frequency, minor overflow from the
       YARP will occur. However, the overflow volume (Tables 4  and 6) is insignificant as
       compared to the river flow and tidal volume during these conditions. Thus, any runoff
       overflow from the YARP during extreme events and during plant shutdown conditions
       will have insignificant impact on the Broward or St. Johns Rivers.

•     The peak discharge rate from the YARP to the river during plant shutdown (2 cfs during
      a 25-year and 4 cfs during a 50-year  storm, Table-6) is insignificant compared to the St.
      Johns River flood flow of 87,000 cfs.  With the plant in operation the peak overflow
      during a 50-year 24-hour storm is 3 cfs and only about 0.3 cfs during a 25-year 24-hour
      storm (Table-4).
                                       11
H-13

-------
 X.    CONCLUSIONS
 The following conclusions can be drawn from the above discussed information.

 •     The pumping capacity from the SARP will be increased to 1,200 gpm from an existing
       capacity of 500 gpm.

 •     An emergency water storage tank with a capacity of 1  million gallons will be used to
       store additional water from the SARP when  the plant is not operating.

 •     During plant operation all water from SARP will be  pumped to the zero discharge
       facility.
                                          •
 •     When the plant (turbine generator) is not in operation, water from the SARP will be
       pumped to the emergency water  storage tank.

 •     The SARP and the emergency storage water tank can hold runoff generated by up to 11.5
       inches of rainfall  from a 24-hour storm, which is more than  the quantity generated by
       a 50-year storm.

 •     During normal operation, the yard area runoff is stored in the YARP and used in the
       plant. The runoff does not overflow to the river during a 10-year storm.. Even for a 25-
       year and 50-year, 24-hour storms, the overflow volume from the YARP is very small.
       The overflow lasts for 5 hours during 25-year storm and for about 13 hours during 50-
       year storm.

•      During extreme events  when the plant is shutdown,  the effect of overflow from the
       YARP on the St. Johns River will be insignificant due to  the small volume of the
      overflow and the large flow in the river.

•     The YARP can hold runoff generated by up to  8 inches of rainfall storm without any
      overflow during plant shutdown condition. ~Eight inches of precipitation in a 24-hour
      period occurs approximately once in  13 years.


                                       12

-------
 XI.   REFERENCES
 1.     St. Johns River Water Management District (SJRWMD), Technical Publication SJ 88-3,
       "Rainfall Analysis for Northeast Florida,  Part VI:  24-Hour to 96-Hour Maximum
       Rainfall for Return Periods 10 Years, 25 Years, and 100 Years", May 1988.

 2.     U. S. Army Corps  of  Engineers,  "HEC-1,  Flood Hydrograph Package, Computer
       Program",  September, 1990.

 3.     USGS Water Supply  Papers "Compilation of Records of Surface Waters of the United
       States, Part 2-B, South Atlantic Slope and Eastern  Gulf of Mexico Basins, Ogeechee
       River to Pearl River".

4.     Anderson, W. and Goolsby, D.A., "Flow and Chemical Characteristics of The St. Johns
       River at Jacksonville, Florida", Florida Department  of Natural Resources, Information
       Circular No. 82, Tallahassee, 1973.

5.     St. Johns River Water Management District (SJRWMD), Technical Publication SJ 86-3,
       "Rainfall Analysis for Northeast Florida, Part I: 24-Hour to 10-Day Maximum Rainfall
       Data", June 1986.

6.     St. Johns River Water Management District (SJRWMD), Technical Publication SJ 86-4,
       "Rainfall Analysis for Northeast Florida,  Part H:  Summary of Monthly and Annual
       Rainfall Data", July 1986.
                                        13

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TABLE-1  STORAGE AREA RUNOFF POND (SARD STAGE-STORAGE*
ELEVATION, ft
7.0
8.0
9.0
10.0
11.0
12.0
13.0
AREA,
acres
1.26
1.32
1.40
1.46
1.53
1.60
1.70
TOTAL VOLUME,
acre-ft
0
1.29
2.66
4.08
5.58
7.15
8.80
NET VOLUME" ABOVE
SILTATION '
ALLOWANCE, acre-ft

0
1.37
2.79
4.29
5.86
7.51
  *     These volumes do not include one million gallons (3.07 acre-ft) volume of the
       emergency water storage tank.

  **    Siltation allowance from El. 7 ft to H. 8 ft.

-------
TABLE-2  YARD AREA RUNOFF POND (YARP) STAGE-STORAGE
ELEVATION, ft
7.0
8.0
9.0
10.0
11.0
12.0
13.0
AREA, acres
1.10
1.25
1.41
1.59
1.79
1.99
2.19
TOTAL VOLUME,
acre-ft
0
1.17
2.49
3.99
5.67
7.57 •
9.65
NET VOLUME* ABOVE
SILTATION *
ALLOWANCE, acre-ft

0
1.32
2.82
4.50
6.40
8.48
    Siltation allowance from H. 7 ft to El. 8 ft.

-------
TABLE 3.  SUMMARY OF RUNOFF ANALYSIS AND STORAGE AREA RUNOFF
         POND (SARP) WATER LEVEL DURING PLANT OPERATION
CASE A:   PLANT OPERATION WITH PUMPING FROM SARP
Storm
Frequency,
Years
24-hour
Rainfall,
inches
Runoff,
inches
Pond Water Level Data
Max. Water Level
Hev. , ft NGVD
Peak
Outflow, cfs
A. STORAGE AREA RUNOFF POND (SARP)
A 1 pjTMPTNfi at 500 mm FROM POND
10
25
50
7.46
9.34
10.8
5.69
7.51
8.9
10.84
11.82
12.2
0
0
2
A2 PUMPING at 700 ppm FROM POND
10
25
50
7.46
9.34
10.8
5.69
7.51
8.9
10.67
11.58
12.15
0
0
1
AT PUMPING at 1 -000 ppm FROM POND
10
25
50
7.46
9.34
10.8
5.69
7.51
8.9
10.52
11.37
12.05
0
0
0.2
A4 PUMPING at 1.200 com FROM POND
10
25
|50
«
7.46
9.34
10.8
5.69
7.51
8.9
10.43
11.27
11.94
0
0
0
===s^=s^xs

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TABLE 4.  SUMMARY OF RUNOFF ANALYSIS AND YARD AREA RUNOFF POND
         (YARP) WATER LEVEL DURING PLANT OPERATION
CASE B:   PLANT OPERATION WITH PUMPING FROM YARP
Storm
Frequency,
Years
24-hour
Rainfall,
inches
Runoff,
inches
Pond Water Level Data
Max. Water
Level Elev. ,
ftNGVD
Peak
Outflow,
cfs
Estimated
Overflow
Volume,
cubic feet
(GALLONS)
YARD AREA RUNOFF POND (YARP) PUMPING AT 500 gpm
•
10
25
50
7.46
9.34
10.8
5.69
7.51
8.9
11.15
12.06
12.28
0
0.3
3
0
9,105
(68,100)
67,975
(508,460)

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TABLES.   SUMMARY OF RUNOFF ANALYSIS AND SARP WATER LEVEL
          DURING PLANT SHUTDOWN
CASE C:   PLANT SHUTDOWN WITH PUMPING FROM STORAGE AREA RUNOFF
         POND (SARP) TO EMERGENCY WATER STORAGE TANK*
Storm
Frequency,
Years


24-hour
Rainfall,
inches


Runoff,
inches


Pond Water Level Data

Max. Water
Level Elev. ,
ftNGVD
Peak
Outflow,
cfs
Minimum
Volume Pumped
to Emergency
Storage water
Tank cubic feet
(GALLONS)
STORAGE AREA RUNOFF POND (SARP) .
10
25

50

7.46
9.34

10.8

5.69
7.51

8.9

11.54
12.00

12.00

0
0

0

0
41,820
(312,820)
96,700
(723,300)
    * Volume of Emergency Water Storage Tank = 1 million gallons

-------
TABLE 6.  SUMMARY OF RUNOFF ANALYSIS AND YARP WATER LEVEL
          DURING PLANT SHUTDOWN                          ^v*^


CASED:    PLANTSHUTDOWNWITHNO PUMPING FROM YARD AREA RUNOFF
          POND
 Storm
 Frequency,
 Years
24-hour
Rainfall,
inches
Runoff,
inches
Pond Water Level Data
Overflow
Volume, cubic
feet
(GALLONS)
                               Max. Water
                               Level Hev. ,
                               ftNGVD
 YARD AREA RUNOFF POND (YARP)
                                                   64,900
                                                   (485,000)

-------
                                                 AT
YEAR
         CUBIC FEET
        =======

         MAXIMUM


        ==

        3,710 x 106
        4,720 x 106
        •—^—B^-*.^—••.

        3,990 x 106
        •"^—^——..^-,—

        3,710 x 106
        ——————.

        3,340 x 106
        —^—

        3,600 x 106
        	•	

        3,340 x  106
        ——*—

        3,390 x  106
        —^————

        3,460 x 106
       •—————.

        3,340 x 106
       -

        5,280 x 106
       ——•—^^—_

       3,430 x 106
       ————•——

       3,430 x 106
       	

       3,310 x 106
       3,670 x 106
       3,760 x  106
      —^—•——_

       4,200 x  106
FL°W VOLUME, I UPSTREAM FLOW VOLUME,
  MINIMUM


  =====

   970 x 106
  '

  1,060 x 10s
 1,010 x 106
  •• •^^••^•^•B


   830 x 106
  -^—^——^i™


   890 xlO6
  —^—^—^—^«^M


   570 x 106
  •'  —i—•—^


   750 x 10*
  540 x 106
 •^—^—^—_i


  810 x 106
 •


  840 x 10*
 ™^^^^-^™«—«



 •^-^-^—•—^—™»«


  890 x 106
 —^-^—^-^«^_


 740 x 10*
 •^^^i^HI^H^HM^


 710 x 106
 ^•^^«^^^^-^^™^™


 390 xlO6
 l,050x 106
 ^•^•^     !•


 780 x 10*
  MAXIMUM


 =====

  3,250 x 106
 —^^-^—^-^

  3,060 x 106
 3,350 xlO6
 •^——-^—^—«^™


 3,480 x 10*
 ———-^—*^™


 2,980 x 106
 ••^—^—^-^—^—.


 2,850 x 106
 —  —•^—^.—^^


 3,000 x 106
 -^^-^^^—^^^-^—


 2,910 x 106
     ——^—


 3,270 x 10*
 •^—^-^—^—-^^^—^™


 3,350 x 10*
 —^^—_


 4,410 x  106
 -^—^——^—^


 3,320 x  106
 ^^^*—vi^n


 3,220 x 106
-—•—-^^•^—^-«


 3,230 x 10*
          .._


 3,510 x  106
•"""••^-^——^^^^•^


3,250 x  106
3,140x 106
      MINIMUM


      =====


       760x10*
      ^^—^-^-^•^^•.»

       580 x 106
      ———

      1,000 xlO6
      •———•—•».

       700 x 106
      —^———™«-

       610 x 106
      •——^—^——•

      400 x 106
                                        120 x 106
      610 x  106
      950 x 106
      —^—^——^—.


      150 x 106
      •™^~™—«^™^».



      —^———^^—


      50 x  106
      310 x 106
      640 x 106
     ^-^^-^-^—.^^

      620 x 106
         From Reference 3 for U.S.G.S. Stream Flow Gaging

         Johns River at Jacksonville, Florida.
      210 x 106
     ^i^M


      130 x 106
     =^BB^BB:B



Station No. 02-2465, St.

-------
TABLE 8.   FLOW STATISTICS FOR St. JOHNS RIVER* AT JACKSONVILLE,
          FLORIDA
Statistic
Average discharge, cfs
Average net discharge, cfs
Maximum daily net flow, cfs
Minimum daily net flow, cfs
Average volume per tidal cycle, eft
Average net volume per tidal cycle, eft
Maximum volume per tidal cycle, eft
Direction of Flow
Downstream
46,419
5,883
87,000
N/A
2,075.5 x 10«
263.1 x 106
5,280 x 106
Upstream
40,536
N/A
N/A
51,500
1,812.4 x 10*
N/A
4,410 x 106
          * From Reference 4.
                             \4-io3

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TABLE 9.  PRECIPITATION AT JACKSONVILLE, FLORIDA*
               Jacksonville Aiiport Precipitation, inches


                       -1984)
Minimum
(Year 1917)
 * From Reference 6, SJ 86-4.

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                                                         >****•—"I;£^Y;'L-
                                                         *   I x-x.  • J/^  / l'^»
                                     '     .   ,

                                     PLANT LOCATION
                                     .--.
                             ^UM^rV^Ox^ ^^.
                             • • •£~?i(^5tJj&~-r>^
^rib^^ni  fK~>ttg

"H ^/S^>^
 > ~!« •
^'-  HX
                                           ^^   •
                                           -         ""    M-.             s

                                           1. CEDAR BAY PROJECT LOCATION AND VICINITY MAI»


                                                            ^ - -;
                                                                  (\

-------

                                          •' i _ _ '    •• rr~^^^*j~*•—-i-
                                                     JJm««terM Wto
   STORAGE AREA RUNOFF DRAINAGE
         BOUNDARY
                                                                                                    YARD AREA RUNOFF
                                                                                                    DRAINAGE BOUNDARY
                                                                            Additional Stereo* Votum* In
L_
DNehM Draining to YARP   '    /

     CEDAR BAY COGENERATtON PROJECT
     FIGURE 2.  SITE PLAN

-------
 Q.I       Confirmation that there is  no  potential  for water  in
           ponds to infiltrate into groundwater.

 RESPONSE:

           The  storage area runoff pond  (SARP) along with  the area
           occupied by coal pile,  the  ash pelletizing area and the
           ditches  conveying the stormwater runoff  to the  SARP are
           lined with a flexible membrane liner.  The presence of
           the  liner prevents infiltration from this pond  to
           groundwater.

           The  yard area runoff pond (YARP) collects runoff from
           the  power block  facilities  and is not lined and will
           result in some infiltration to the groundwater.  The
           water from this  pond is pumped to the zero discharge
           facility.   Thus,  during plant  operation  the pond is
           maintained in an almost empty  condition  which minimizes
           the  infiltration to groundwater.


Q.2        Confirmation that pumping of stormwater  from unlined
           pond will  not draw in groundwater.

RESPONSE:

           The  pumping from the YARP is limited to  El.  8 ft.
           Based on the  limited groundwater elevation data
           observed during  initial  soil investigations,  the water
           level in yard area  runoff pond is between El.  5 ft to
           El.  7  ft.   By limiting the pumping from pond to El. 8
           ft and above, withdrawal  of groundwater during pond
           pumping is  precluded.

Q.3        Response to FEDER concern about pH control for coal
           pile  during potential episodic events where overflow
           from  SARP could occur.
RESPONSE:
          In order to provide pH control for the coal pile area
          runoff, for events greater than the 50-year 25-hour
          storm, the runoff collection ditches in the coal pile
          area will be provided with about a 3 inch thick
          limestone layer.
                          •U -107

-------
Q.4       Priority use status of stormwater vs. SKC wastewater
          for Cedar Bay cooling.
RESPONSE:
          The logic of the system will be set up in such a way
          that stormwater takes priority over all other available
          sources.  The water sources in decreasing order of
          preference are:
                    Stormwater Runoff

                    Plant Waste Water

                    SK Effluent
          During the period when stormwater from the ponds is
          available, the use of SKC wastewater will be reduced to
          accommodate the use of stormwater from the ponds.

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           APPENDIX I

CEDAR BAY ZERO DISCHARGE SYSTEM
     SUMMARY DESCRIPTION

-------

-------
                     TABLE OF CONTENTS

                                                      TAB

 INTRODUCTION  	1

 SUMMARY DESCRIPTION	 2

 SYSTEM DESIGN CRITERIA	3

 WATER BALANCE  	4

 WASTE STREAM DATA	5

 SYSTEM DESCRIPTIONS AND FLOW DIAGRAMS	6

      Cooling Tower Makeup Pretreatment System
      Cooling Tower Slowdown Treatment System
      Reverse Osmosis System
      Evaporator/Concentrator System
      Crystallizer and Centrifuge System

 PLANT LAYOUT	7

 PIPING AND INSTRUMENT DIAGRAMS (P&IDS)	8

   •   Cooling Tower Makeup Pretreatment-System M74-LG01
   •   Cooling Tower Slowdown Treatment and
      Preconcentrator System M74-LG02
   •   Evaporator/Concentrator System M74-LG03
   •   Crystallizer and Centrifuge System M74-LG04

SPECIFICATIONS	9

      Cooling Tower Makeup Pretreatment-System M110
      Cooling Tower Slowdown Treatment-System
      Preconcentrator System (Pressure Filler and Reverse
      Osmosis System) M126
      Evaporator, Crystallizer and Centrifuge System M125
      Attachments to Technical Specifications
                                                          Rev. A

                     I-

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 VENDOR PROPOSALS	        1(J

   •  Infilco Degremont, Inc.
      (Slowdown and Pretreatment Systems)


   •  Resources Conservation Company (Evaporator/Crystallizer)
   •  Glegg Water Conditioning, Inc. (RO System)

OTHER INFORMATION
                                                           Rev. A

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                               INTRODUCTION
 The Cedar Bay Cogeneration Plant is a coal fueled facility located on an existina
 Semmole Kraft (SK) Paper Mill site in Jacksonville,  Florida.                   9


 The project will be designed to provide up to 380,000 pounds per hour of process

 steam to the SK plant and 1 250 MW (net) of electricity which will be wheeled?h?ough

 he Jacksonville Electric Authority System for exclusive sale to Florida Power and
 Light Company.



 f^H-layH K ? Ih€! Plantjacilities js shown in Tab 7-  Th* Plant will burn coal in a
 flu dized bed boiler and will use a cooling tower for heat rejection.  Coal will be

 ,nei'chred t0 the nite by rail and limestone fay truck.  Ash generated will be stored
 in ash silos or pellet.zed and temporarily stockpiled on-site prior to being conveyed
 to the mine source by rail for disposal.
             -n            .                           ™<* plant wastewater,
         cooling tower blowdown, coal, limestone, and ash pellet  storage area
runoff, yard area runoff, and low volume plant wastes (boiler blowdown, floor
drains, and demineralizer regeneration wastes) will be treated and reused in the
piant.


Seminole Kraft waste water is used for makeup to the plant's cooling tower.
                                                                   Rev. A

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              CEDAR BAY ZERO DISCHARGE SYSTEM
                      SUMMARY DESCRIPTION
 General
 Wastewater  generated  in the  Cedar Bay plant  from  floor drains, makeup
 demineralizer regeneration, material storage area storm  water runoff and from
 operation of the wastewater treatment system plus Seminole Kraft Company (SK)
 wastewater will be treated in pretreatment system for use in the Cedar Bay and SK
 cooling towers. The treatment method will be lime soda softening.

 Cedar Bay boiler blowdown will be reused as cooling tower makeup without
 treatment.

 Blowdown from the Cedar Bay cooling tower and general site stormwater runoff will
 be treated in the zero discharge system and reused as cooling tower makeup. The
 treatment method will be lime soda softening, filtration, reverse osmosis (RO)
 evaporation and crystallization.

 Dewatered sludge from the pretreatment and the cooling tower blowdown clarifiers
 and crystallizer salt will be disposed of offsite.

 There will be no process wastewater discharge from the Cedar Bay plant.


 Cooling Tower Makeup Treatment

 The cooling tower makeup treatment system will process the Cedar Bay plant
 wastewater and SK treated process wastewater to allow the cooling tower to be
 operated at reasonable cycles of concentration without excessive heat transfer
 surface fouling. The cooling tower makeup treatment system will take the available
 Cedar  Bay plant wastewater and use SK wastewater to supplement the cooling
 tower makeup requirement.

 Wastewater will be received in a premix tank to allow the addition of chemicals to
 condition the wastewater  before clarification. Water from the premix tank will flow
 to the clarifier for suspended solids removal.  Chemicals can also be added to the
 clarifier if required.  Clarified wastewater will flow to a  clearwell before being
 pumped to the cooling towers. The pH of the treated wastewater will be adjusted
 if required.

The chemicals that will be  used  in treatment  include  sulfuric acid for pH
adjustment, lime and soda ash for softening, aluminum or iron salts for coagulation,
and polymers as coagulant aids.
                                  2-1                            Rev. A

-------
 Sludge from the clarifier will be thickened and dewatered for offsite disposal.

 Zero Discharge Wastewater Treatment

 The zero discharge treatment system will process the Cedar Bay cooling tower
 blowdown for reuse as cooling tower makeup. The primary function of the system
 will be the  removal of the  salts  that build  up in the cooling water due to
 evaporation.

 Cooling tower blowdown will  be treated in a clarifier operated as a softener to
 pretreat blowdown for use as RO feed water. Lime, soda ash, sodium hydroxide
 and magnesium chloride will be added to the softener as required to reduce the
 calcium and silica concentrations to acceptable levels. The softened cooling tower
 blowdown will be pH adjusted with sulfuric acid, and filtered to prevent suspended
 solids fouling of the RO system.  Sludge from the clarifier will be thickened
 dewatered and disposed of in a landfill.

 The filter effluent will be chemically conditioned with sulfuric  acid and a scale
 inhibitor chemical such as polymers or sodium hexametaphosphate to reduce the
 potential for RO membrane fouling. The RO unit removes salt from the blowdown
 and produces a product stream low in total dissolved solids (TDS), and a brine
 stream, high in TDS. The RO product stream is returned to the cooling tower for
 reuse.  The RO brine is pH adjusted and treated in the evaporator to produce a
 low TDS condensate stream and a very high TDS brine stream.

 Additional evaporator chemical feeds  such as  antifoam agents, and  sodium
 hydroxide will be used if required.

 The evaporator condensate is returned to the cooling tower for reuse, and the
 evaporator brine is treated in the crystallizer. The crystallizer produces a low TDS
 product and solid salt crystals. The crystallizer product is returned to the cooling
tower for  reuse.   The  solid  salt from the  crystallizer is  disposed of offsite.
Additional crystallizer and evaporator chemical feeds such antifoaming agents, and
sodium  hydroxide will be used if required.
                                  2-2                             Rev. A

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                           DESIGN CRITERIA
  Th,s section contains the principal criteria for the detail design of the Facility  The
  des,gn elements (e.g., size, layout, ratings, quantities, materials of construction
  equ,pment types) described are approximate.  Changes may occur as detai.ed
  design progresses.

  CODES AND STANDARDS

 Systems  and equipment will be designed in accordance with the applicable
 secfons  of the codes, standards,  and regulations  in  effect  at the date  of
 construction.  Applicable sections of codes, standards, and regulations will be
 defined in specifications.

 COOLING TOWER MAKEUP WATER

The normal cooling tower makeup water supply will be from Seminole Kraft  The
bas,s for systems design considers that water quality shall be as delineated in the
following table:

     Characteristic         Unit    Quality
PH
Alkalinity
Sulfate
Chloride
Solids, Dissolved
Silica
Calcium
Magnesium
Sodium
Potassium
•
Iron
Manganese

mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
6-9
\j—&
565
805
312
2300
55
560
260
650
15
1.1
0.7
                                3~1                             Rev. A
                             I-

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 DESIGN DATA SUMMARY:


      Cooling tower evaporation rate (summer):            2,288 gpm
      Cooling tower drift rate:                           3 gpm
      Seminole Kraft (SK) cooling tower makeup rate:      500 gpm
      Maximum SK wastewater dissolved solids:           2,300 mg/l
      Maximum cooling water dissolved solids:            12,500 mg/l
      Maximum flow from storage area runoff:             1200 gpm
      Maximum flow from general site runoff:              500 gpm
      Cooling tower biowdown temperature range:          64 - 95 °F
      Design Average Biowdown Flow (summer):          530 gpm


 EQUIPMENT SIZING BASIS:


 Cooling Tower Makeup Pretreatment Clarifier:


 The cooling tower makeup pretreatment clarifier will be sized for a maximum flow

 rate of 7 MGD to allow treatment of 50% of the Phase II (open discharge concept)
 flow.


 Cooling Tower Biowdown Waste Clarifier/Sand Filter:


 The cooling tower biowdown waste clarifier and sand filter will be sized to treat

 approximately 175% of the average cooling tower biowdown flow.


 Reverse Osmosis System:


 The reverse osmosis (RO) system will be  sized  to treat the  design summer

 biowdown flow at 65 °F and approximately 125% of the design summer biowdown

 flow at 80 °F.
                                 3-2                           Rev. A

22029VDignCrit                      _J—     (

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    Evaporator/Crystallizer System:

    The evaporator/crysta||i2er syste
    the des,gn average summer cooling tower blowdown flow with an outage allowance
    of 2 days per month.

   Emergency Wastewater Storage Tank:

   Theemergencywastewater storage tank wil, be sized to hold approximately 3 days
   of RO brmg production based on the design summer cooling tower b.owdown flow
   and  a 60% RO product recovery rate.

   MECHANICAL SYSTEMS AND EQUIPMENT

  GENERAL

  This section provides a description of the design criteria for principal mechanical
  equipment and systems.

  PUMPS

  The head/capacity characteristics of pumps will be such that the head continuously
  nses w,th decreasing capacity until a maximum head is reached at zero flow  The
  minimum rise to shutoff will be specified to be at least 120 percent of design head.

 Pumps will be specified to be sized to accept an impeller at least 1/8-inch .arger
 m d,ameter than the supplied impeller without having to change the pump casing
 Permanent or startup strainers wil. be  installed in  the suction piping of pumps
 which operate with close clearances.
                                  3~3                           Rev. A
2202«*gnCri»

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  Pumps over 25 hp and with variable flow requirements will contain a recirculation
  line for pump protection. The recirculation line will normally be routed to the source
  from which the system  is taking suction.

  Pressure Vessels

  Pressure vessels will  be  fabricated in  accordance  with ASME Section  VIII,
  Division 1, Pressure Vessels.

  Pressure vessels will be supplied with the following features:

       a.   Process, vent, and drain connections for startup and maintenance

      b.   A minimum of one manhole and one air ventilation opening on vessels
           where maintenance or cleaning access is required

      c.    Relief valves  in accordance with applicable codes

 Heat Exchangers

 Heat exchangers will be  either shell and tube type-or plate type.  Shell and tube
 type  will be designed with provisions for either tube bundle replacement or
 individual  tube replacement  in place.  Heat exchangers using raw water will be
designed with straight tubes having a minimum diameter of 3/4 inch to  allow
manual tube cleaning in  place.  Thermal relief valves will  be  provided between
isolation valves for the water side of the heat exchangers.
                                                                   Rev. A
                                ~|~ ^ Q

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  Tanks
  Plant tanks will have storage capacities as required by the design of the systems.
  Tank volumes will be equivalent to the stated volume.

       a.    Material and Corrosion Allowances

            Tanks will  be fabricated in accordance with guidelines established by
            API or AWWA, as determined by the service.

      b.    Overflow and Vent Connections

            Overflow connections and lines will be provided where required and will
            be at least  one pipe size larger than the largest input line or combina-
           tion of inputs that can discharge simultaneously.

      c.   Maintenance Drain Connections

           Maintenance drain connections will be provided of an adequate size to
           facilitate drainage of tanks within a reasonable time.

      d.   Manholes and Ladders

           Manholes, where provided, on tanks and pressure vessels will be
           18 inches, except where impractical.  Ladders and cleanout doors will
           be provided on large tanks.
                                   3-5                             Rev. A
220WDignCnt                         ^17 ~ | 0

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 Piping and Valves

 Plant piping design and fabrication shall be governed by the ANSI B31.1 Power
 Piping Code and local plumbing codes.  System frictional pressure drops, .pipe
 sizing, and flow balancing, including the determination of necessary throttling, will
 be determined by using Crane Technical Paper 410, Cameron Hydraulic Data
 Book, and Contractor Mechanical Engineering Standards.

 As a general guideline, piping 2-1/2-inch in diameter and larger will be butt-
 welded,  and piping less than 2-1/2-inch will  be socket welded.  Threaded
 connections  may  be used for  certain low pressure  small  pipe applications.
 Nonpressure buried or embedded drain lines may have bell and spigot joints.

 Pipe stress analyses will be performed on 2-1/2-inch and larger piping operating
 at or greater than 400 °F.  Pipe hangers will be designed for these systems to
 maintain stresses and equipment nozzle loads within allowable limits.

 Where practical, piping 2-1/2-inches in diameter and larger will have supports
 arranged  so  that any length of  pipe or a valve may be  removed without any
 additional supports being required.  Supports will be positioned near valves and
joints that may have to be broken during maintenance.

 Where pipe runs pass through floors or walls, either individually or collectively, floor
 or wall collars or other curbing will be provided.

 Piping systems will be designed with high point vents and low point drains (system
"hot" condition).
                                   3-6                             Rev. A
                                -i—     I I

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  Steam piping will be sloped in the direction of steam flow, with a minimum slope of
  1/8 inch per foot.  Condensate  collection in piping  systems will be avoided by
  installing manual or automatic drain devices.

 Steam lines fitted with restricting devices, such as orifices in the process runs, will
 be provided with drainage upstream of the device such that water does not collect
 in lines.'

 Drains with restricting orifices or steam traps with startup and blowdown drains will
 be installed in low  points of steam lines where condensate can collect during
 operation.

 Drain lines will be sloped at 1/4 inch per foot.

 Means will be provided to fill and clean loop seals.

 A bypass line around control valves will be provided for services that are essential
 for operation. The bypass will be omitted if services  have redundant systems in
 parallel, if manual operation would be extremely difficult, or if plant or equipment
 safety could be jeopardized by  manual operation.

 Instrumentation connections (pressure taps, temperature taps) will be provided for
 mechanical systems. The following components will  be fitted with pressure and
temperature taps:

     a.   Pump suctions and discharges

     b.    Heat exchanger inlets and outlets
                                   3-7                             Rev. A

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  Pressure taps will be supplied with root valves  and temperature taps will be
  supplied with thermowells.

  Instruments will be  provided with air block valves  and  ganged  pneumatic
  instruments will have a single air supply.

  Valve selection will be based on the system conditions (flow, pressure, and
  temperature); application (shutoff, nonreturn, or throttling); and process fluid (water,
  steam, air, gas, chemical, or solids).

  Insulation

 Thermal insulation will be installed on equipment and piping to reduce system heat
 loss, to provide personnel protection, and to prevent condensation. The insulation
 will also function as part of heat traced freeze protection systems.

 Insulation materials will be free of asbestos and will meet the fire and smoke rating
 requirements of NFPA.

 Insulation thickness will be  designed to limit the calculated heat loss to  65 to
 80 Btu/tf-hr and, for hot surfaces in the vicinity of personnel,  to limit outside
 lagging surface temperature to a maximum of 140 °F, based on  100 °F ambient
 temperature and 2-feet-per-second air velocity.   Insulation  materials will be
 calcium silicate and mineral fiber, with aluminum jackets.  Antisweat insulation will
 be furnished with a moisture-proof barrier.  A fluid temperature of less than 50 °F
 will be the  basis for using antisweat insulation.   Insulation located outside of
 buildings and structures will be weatherproofed.
                                    3-8                              Rev. A
220»D«gnCrit                          ~~

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   ELECTRICAL SYSTEMS AND EQUIPMENT

   GENERAL

   The integrated electrical system and interconnection to the main plant are shown
   on the 480 V Switchgear Single-Line Diagram, Drawing No. E73-NG01.

   4 KV AND 480 V SYSTEM AND EQUIPMENT

   The 480 V switchgear transformers and the compressor motors will be supplied
   from the main plant 4.16 kV switchgear.

  The transformers will be outdoor, cast coil type 3-phase, 60 Hz, AA/FA cooled,
  delta-connected,  primary/solidly grounded wye connected secondary.

  Motors below 250 hp fed from MCCs will be controlled by breaker-protected
  combmation starters. Start and stop controls for MCC fed motors will be through
  the PLC with  local pushbutton control at the MCC starter.

  MCCs located in  the building  will have  NEMA 12 (or equivalent) enclosures
  Where local contactors or outdoor MCCs will be employed, NEMA 4 and 3R
 enclosures will be  provided.

 MOTORS

 Motors will be the squirrel-cage-induction type designed for full voltage starting.

 In general motors 250 hp through 2,500 hp will be rated 4 kV for use on a 4.16 kV,
 3-phase, 60 Hz, resistance-grounded system.  Motors 3/4 hp  through 200 hp'
 selected 250 and 300 hp motors, and reversing  fractional motors will be rated
                                 3~9                           Rev. A
220»DiflnCril                         "\~ — I U-

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460 V, 3-phase, 60 Hz for use on a 480 V solidly grounded system. Single-phase
motors smaller than 3/4 hp will be rated 115V, single-phase, 60 Hz for use on a
nominal 120 V solidly grounded system.

Motors will be rated for continuous operation at full load and Class B temperature
rise.  Motors will be provided with a service factor in accordance  with NEMA
MG1 -12.47. Motor horsepower ratings will be selected without taking credit for any
service factor above  1.0 under any continuous operating condition.

Motors will be capable of starting and accelerating the load to  full speed with
80-percent rated motor voltage at the motor terminals.  In general, locked rotor
kVA/hp will be NEMA Code G or  less for motors rated for continuous duty.

Totally enclosed fan-cooled motors will be provided in high-dust environments.
Weather-proofed NEMA Type II enclosures will be provided for all outdoor medium
voltage  motors.   Motors located outdoors and rated 50 hp  or larger will  be
furnished with space heaters that are automatically energized when the motor is
idle. Motors installed in hazardous areas will meet the requirements of the NEC.

GROUNDING

Grounding will conform with the requirements of the NEC.

Motors rated 460 V  and higher  will be provided with a supplementary ground
connected to the ground grid. Skid-mounted motors will be considered grounded
if the frame of the skid is grounded.  Motors mounted on or attached directly to
building steel will be considered adequately grounded. Motor-operated valves will
be considered grounded by the piping system. In general, freestanding enclosures
containing electrical equipment will be supplied with a ground  bus which will be
connected  to the ground grid.   Wall-mounted enclosures containing electrical

                                  3-10                            Rev. A
22029iDi0nCril                         -L-

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    equ,pmem win  be furnished with . grounding lug.  Local  oortrol  stations and
    instruments «• be grounded through the raoeway system.  Enclosures attached
    .0 struct  steel will be  considered adequately  grounded.   Skid-mounted
    enclosures will be considered adequately grounded through the framework of the
   stod which will be connected to the ground grid or grounded  structural steel!

   HEAT TRACING

   Electrical heat tracing will be provided for caustic piping. Electrical heat tracing will
   be the self-regulating type, wherever possible, and will be provided with necessary
   power distribution equipment.  Indicating lights will be provided for each circuit to
   indicate power is available.
  CONTROL SYSTEMS AND EQUIPMENT

  GENERAL
  Control and  instrumentation for the Facility will permit normal operation  by
  operators in the control room and will provide local controls in discrete areas as
  required.
 Control subsystems,  including programmable logic controllers (PLC) (and man
 machine interfaces), will be provided for overaJI control  of the zero discharge
 CENTRAL CONTROL ROOM

 A centra, control room will house the PLC-based control stations, man-machine
 interfaces, alarm and graphic printers.
                                  3"11                            Rev. A
22a29\DtgnCrit                         _  —J

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 An electrical equipment room will contain the I/O cabinets for the PLCs and an
 UPS system.

 The control  will  be by  a microprocessor-based PLC  system  and  includes
 hardware, software, and associated peripheral equipment to monitor, control,
 display, alarm, record, log, and trend process facility inputs.

 The graphic displays will be designed to present the process data and status of the
 subsystems in a manner to effectively support ergonomic responses.  Alarms will
 be prioritized statically and dynamically.  Following an alarm, the operator can
 silence the horn, acknowledge the alarm, and direct the screen and control cursor
 to the appropriate display to ascertain the use of the  alarm and take corrective
 action.

 The displays will be developed to provide a cohesive view of the facility processes.
 Overview displays will be developed to present overall process parameters.  More
 limited view  graphics will be provided for operating and startup examination of
 subprocesses.

 Printers will be provided for data logging and reporting  functions.

 A port for communicating with the main plant DCS will be provided. The capability
 to transmit data will be available.

 MAN-MACHINE INTERFACES

 The man-machine interfaces will be provided for control and display purposes.
 The software used will  have the  capabilities for trending,  data acquisition, and
 storage as required.  Touch screens will  enable the operator to view graphics, log
 and respond to alarms, and control the subprocesses. Alarm and graphic printers

                                   3-12                             Rev. A
2202«fc9nCrit                         4—   *  f

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  will enable the operator to obtain hard copies of alarm summaries, historical data
  and graphics.

  ALARM MONITORING

  The operator will be alerted to abnormal conditions by alarms through the MMI
  stations and by alarm printer(s). The MMI stations will access all the information
  transmitted on the PLC highway. Alarms will display on the MMI CRTs in order of
  priority.

  CIVIL/STRUCTURAL/ARCHITECTURAL FEATURES

  GENERAL

 This section describes the general criteria and layout, the design of structure and
 equipment  supports, and associated architectural features  of the Facility's
 buildings.

 STRUCTURAL DESIGN CRITERIA

 Dead Loads

 The dead loads include the weight of framing, roofs, floors,  walls,  partitions,
 platforms, and all permanent equipment and  materials. The vertical and lateral
 pressure of liquids will also be treated as dead loads.

 Live Loads

Approved floor load capacity signs will be posted for all roofs, platforms, or floors
except slab on ground in accordance with the Occupational Safety and Health
                                 3-13
                                                                 Rev. A

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   Standards, Subpart D, Walking and Working Surfaces.  Design live loads will be
   shown on the respective design drawings.
  The uniform design live loads will be:
       Roofs                                            30 psf
                                                         75 psf
       Assembly and locker rooms                         100 psf
       Stairs, platforms, and walkways                     100 psf
       Ground floors - General areas                      250 psf
       Surcharge adjacent to plant structure                 250 psf (truck)
                                                         650 psf (railroad)
       Truck support structure                             AASHTO HS20
                                                         loading
       Grating or checkered plate platforms                 150 psf
       Concrete  platforms                                250 psf

 An additional 3 kips  concentrated load will be applied on all floor beams to
 maximize moment or shear. This load is not cumulative to columns and it is not
 applied on stairs and landings.

 Elevated concrete slabs will be designed to support the prescribed live load or a
 concentrated load  of 3 kips,  whichever produces  the greater stress.  The
 concentrated load will  be treated as a uniformly distributed load over an area of
 2.5 square feet, located to produce the maximum stress  conditions in the slab.
                                   3~14                             Rev. A
2202«>iflnCril

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 Design Basis

 All steel structures will be designed by the working stress method. Soil bearing
 pressure will be checked  for the actual loads.  Reinforced concrete will  be
 designed using the ultimate strength method.

 A minimum factor of safety will be provided for all earth retaining structures  as
 shown below:

      Overturning                1.50
      Sliding                    1.25
      Buoyancy                  1.15

 Design characteristics assumed for the various materials are in accordance with
 Standard Building Code from the Southern Building Code Congress International,
 AISC, ACI, and local codes.

 CONSTRUCTION MATERIALS AND ALLOWABLE STRESSES

Concrete and Grout

Concrete and grout design compressive strengths as measured at 28 days will be:
     Structural concrete for spread footings, mats, and
     slabs on grade                                             3f000
     Structural concrete for elevated slabs, columns, walls,
     and elevated tanks                                         4,000
                                 3-15                            Rev. A

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      Electrical duct encasement or lean concrete backfill             2,000
      Nonshrink grout                                             4,000

 Reinforcing Steel

 Reinforcing steel bars will be deformed, billet steel, conforming to ASTM A 615,
 Grade 60. Welded wire mesh (WWM) will conform to ASTM A 185.

 Structural Steel

      •     Structural steel shapes and plate will conform to ASTM A 36.

      •     Structural pipe members will conform to ASTM A  53, types E or S,
           Grade B or ASTM A 501.

      •    Allowable stresses in structural steel will be determined in accordance
          with AISC Code.

 ARCHITECTURAL CRITERIA

 Layout

 Access aisles and clearances will be provided for operation,  maintenance, and
 equipment removal (i.e., heater tube pulling space, pump motor removal space).
 Provisions will also be made for personnel walkways to equipment (for routine
 maintenance only), doors, stairs, and other access points.
                                  3-16                            Rev. A
22CB8\D«gnCrit                         3T

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    Siding
    Exterior siding for the new bui.ding wil, be factory assembled pre-insulated stee,
   wall panels or a field erected system.


   Wai, insulation  wi.l be  selected to meet the U-value required by the Energy
   Conservation Codes, where applicable.                        «/™ Energy
   Roofing
  Roof.ng will be desfened to ^stend specified wind Ioadin9 inching calculated
  UP * Roofing „ be pitched no, less than 1/8 inch per too, and wii, drain £
                                                                   codec,
 Thickness of the roof insu,afion wil, be seiected to meet the 0-va.ues required by
 the Energy conservation Codes, where applicable.

 The roofirg wiii be a sing.e-piy membrane roofing system, mechanically attached
 ov r mec an,cal,y fastened rigid polyiso-cyanurate board insuiafon. on a standing
 seam roof with insulation as required.
 Painting
•n general,  ai, exterior and interior surfaces, except surfaces of Kerns and
ewmen, furnished in manufacturers  finish  or «.sh  coat steiniess  J
galvan,zed. aluminum, or nonferrous, will be painted, Including:


     •    All concrete excluding floors and concrete unit masonry) in occupied
          areas in an acrylic latex system.
                                 3-17                            Rev. A

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            Surface of exterior ferrous will receive an exterior prime and enamel
            coating system.

            Surface of interior ferrous and galvanized metals will receive an alkyd
            semi-gloss enamel coating system.

       •    Exposed ferrous surfaces of shop coated mechanical  and electrical
            equipment and uninsulated piping will  receive alkyd  gloss enamel
            coating  system.

            All gypsum board, not receiving vinyl wall covering, will be painted in a
            flat acrylic latex coating system.  Surface preparation  of all ferrous
            metal surfaces will be in accordance with the applicable requirements
            of  the  Steel  Structures  Painting Council  specifications;  surface
            preparation for all other surfaces will be in accordance with the paint or
            coating manufacturer's recommendations.

            As a standard of quality, paints  and coatings will be those manu-
            factured by Carboline, DuPont, Glidden, PPG Industries, Pratt and
            Lambert, Sherwin-Williams, Tnemec Inc., Porter Paint Co., and Con-
            Lux, with color selection by Owner..,

 Provisions, equipment, and accessories for  the physically handicapped will be
 provided in all areas as required by the appropriate building code.
                                                                     Rev. A
22029\DignCfil

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H
M)SC 70 SK COOLING TOWER
PLANT DRAINS
STORAGE 15 /^
RUNOFF ^ Co)
500 \~s
2586 ^*»>inY^"~>\
WASTEWATER I V^yV-^
j 849
vB' PRETREATMENT 2768 2268 3117
« ^ A_^ CLARIFIER
35 vF/
SLUDGE
THICKENER
(PART OF SALT CAKE
CLARIFIER) TO LANDFILL
29
30 35 ^ 1
SLUDGE IT r« - ••
PFWATFRIN« 	 I 	 	 .
i 5 CRYSTAI 1 17FR „
DEWATERED SLUDGE
TO LANDFILL « 	 • .
POTABLE _
VV/MLIt iiecc*
FROM SK USES
70 MISC. •
Ubbb
SK WFI 1
WATER 559 489 DEMIN *37 CONDENSA1
* SYSTEM *" 'TANK
52 456
(G/* 	 '
?,K,r^, 456 » CONDENSA
REGEN WASTE r/tSUNQATP POLISHEI
TO PRETREATMENT CONDNSATE

' EVAPORATION
2290
BACKWASH
.— YARD AREA RUNOFF s~^n f~~\»*
®" » C»)«" G)35
««« OAA COOLING
COOLING 88° «» TOWER 885 ^ F||TFRS
TOWER BLOWDOWN
BLOW CLARIFIER 	 1
BLOWDOWN
500
110
W^ 125 (AW- 250
FVAPORATOR «•• i V_/ rmniirr a

125 FROM
1?c FILTER
EVAPORATOR ^ 	 f""V- ROUNrr 4


110 "& NOTES:
760 FXPORT 1) PROCESS FLOWS ARE
' vw ^ CArWn 1 r\fnrr*Trr\ Tvni/1* At Cl /"\IAI<
	 	 *• QTC »M EXPECTED TYPICAL PLOW;
STEAM |NGpM
2) IANKS, PUMHb AND
[E/ 893 B«H™ flo CHEMICAL FEED SYSTEMS
»QC 	 ^ BOILER . B" 	 ^. ARE NOT SHOW
M!er- _

Im CEDAR BAY
* ' ncciPM
®ucoion
1 	 »/Hj 53 WATER BALANCE
* REGEN WASTE BOILER DIAGRAM
TO PRETREATMENT BLOWDOWN 3/12/93
CLARIFIER DLvjwuwvvH
5


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                        WASTE STREAM DATA
 Wastewater Streams
 The wastewater streams generated at the Cedar Bay Plant are as follows: '

 1)   Boiler blowdown
 2)   Demineralizer regeneration waste
 3)   Miscellaneous plant drains
 4)   Storage area runoff
 5)   Yard area runoff
 6)   Wastewater treatment system drains
 7)   Cooling tower blowdown
 8)   Chemical cleaning waste

 These wastewater streams are used as follows:

 1)   Boiler blowdown is sent directly to the cooling tower basin without treatment
      for reuse as cooling tower makeup.

 2)    Demineralizer regeneration waste is neutralized, softened in the cooling tower
      pretreatment system and reused as cooling tower makeup.

 3)    Miscellaneous plant drains are softened in the  cooling tower pretreatment
     system  and reused as cooling tower makeup.

 4)   Storage area runoff is collected in the storage area runoff basin.  When the
     turbine  generator is  in operation, it  is softened  in  the  cooling  tower
     pretreatment system and reused as cooling tower makeup. When the turbine
     generator is not in operation, it is sent to the emergency water-storage tank
     and held until it can  be treated in the pretreatment  clarifier, cooling tower
     blowdown clarifier or evaporator system for reuse as  cooling tower makeup.

5)   Yard area runoff is collected in the yard area runoff basin. When the turbine
     generator is in operation, it is pumped into the cooling tower blowdown line
     where a portion of it is softened in the cooling tower  blowdown system and
     the remaining portion  is used as evaporator crystallizer non-contact cooling
     water. When the turbine generator is not in operation,  it is storage in the yard
     area runoff basin until the it is needed for cooling tower makeup. All the yard
     area runoff water is reused as cooling tower makeup except for runoff in
     excess of a 25 year 24 hour storm with the turbine generator in operation and
     a 10 year 24 hour storm with the turbine generator out of operation
                                                                  Rev. A

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 6)   Wastewater treatment  system drains are softened  in the cooling tower
      pretreatment system and reused as cooling tower makeup.

 7)   Cooling tower blowdown is treated in the zero discharge system for reuse as
      cooling tower makeup. The cooling tower blowdown is softened, filtered, and
      desalted in a reverse osmosis (RO) system. The RO product water (low
      dissolved solids) is reused as cooling tower makeup.  The RO reject water
      (  high dissolved solids) is farther concentrated  in the evaporators.  The
      evaporator distillate is reused as cooling tower makeup and the evaporator
      concentrate  is processed in  the crystallizer.  The crystallizer produces a
      distillate that is reused in the cooling tower and solid salt that is disposed of
      offsite.

 8)   Chemical cleaning waste is disposed of offsite. The rinses following chemical
      cleaning will  be reused as cooling tower makeup or disposed of offsite.

 All the wastewater streams generated in the Cedar Bay facility, except yard area
 runoff in excess of the design storm events, are reused  as cooling tower makeup.
 Seminole Kraft (SK) wastewater is used to supply all cooling tower makeup
 requirements in excess of that which can be supplied by the Cedar Bay wastewater
 streams.  There is no discharge of  process wastewater generated at Cedar Bay.

 The expected average flows for each of the wastewater streams are listed  in
 Table 1.

 The average demand for  Cedar Bay cooling tower makeup is expected to be
 approximately 3,200  gpm,  including  recovered cooling  tower  blowdown.
 Additionally, SK is  expected to reuse 400 to 500 gpm of treated wastewater from
 the Cedar Bay pretreatment system as makeup to  the SK cooling tower.

 The quality of the mixed wastewater feed to the  pretreatment system and effluent
 quality expected from the pretreatment clarifier and the cooling  tower blowdown
 clarifier after filtration are listed in Table 2.

 Solid Waste Streams

 The wastewater treatment plant produces one sludge stream from the filter press
 (dewatered pretreatment and cooling tower blowdown clarifier sludge) and one and
 solid salt stream from the centrifuge (dewatered crystallizer  slurry).

The pretreatment and cooling tower blowdown clarifier sludge is collected in the
thickener portion of the pretreatment clarifier and pumped on a batch basis to the
filter press.  The  solids in the  sludge are captured on cloth filters in the press as
the pump forces the sludge through the filters. Sludge is  pumped to the filter press
until it is filled with  solids. The plates holding the filters  are  then opened and the
sludge is dropped into a sludge container.  The filter press is expected to produce
                                   5-2                             Rev. A
                               r-O-7

-------
 sludge containing 40 to 60 percent solids. With the design analysis water  the

                   ~' to * «*•*"» 7S - •» * ^ « <°
 The soluble salts in the cooling tower blowdown are concentrated to the point that
 they are precipitated as crystais in the crystallizer.  The slury - forme? ta the
 cwaHiajr IB pumped to the centrifuge where the crystals are removed from the
 slurry and dewatered  The concentrated liquid from the wnm^ets returned to
 a £222 2Th  Th? Hd6Watered Salt **** drop b* 9ravi* from the centrifugl £
 faS«  Z;TheH°"dS "^f nt °f the ""» is expected to ta jn the 85 to 90 peFcent
 range. With the des.gn analysts water, the solid salt production is expected to be
 approximately 30 tons per day based on 85 percent solids salt.

 The filled sludge and salt containers will either be hauled directly to the approved

 STS^'K'ST' at "" ^ ^ ste UIrt1 *" ™ ^ Ll9d

 The dewatered clarifier sludge will consists primarily of calcium carbonate and
 magnes.um hydroxide from  the  lime soda softening reactions. The  dewatered
 crystallizer salt will consist primarily of sodium sulfate and sodium chloride  The
 expected characteristics of the clarifier sludge and crystallizer salt are listed in
If 2? i*  «   S «dge and salt characteristics were estimated based on an analysis
of SK clarifier effluent from samples taken on February 10, 1993. The SK clarifier
is the treatment unit ahead of the SK lagoons
                                5~3                            Rev. A
                             I-22

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                 Table 1
Cedar Bay Expected Average Wastewater Flows
STREAM
Boiler blowdown
Demineralizer regeneration waste
Miscellaneous plant drains
Storage area runoff
Yard area runoff
Wastewater treatment system drains
Cooling tower blowdown
Chemical cleaning waste
FLOW GPM
53
52
70
15
20
50
900
0
                   5-4   X-21
Rev. A

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         Expected
         BOB	


  Constituent
                Table 2

Mixed Wastewater and Treated Wastewater
Quality
                                   Pretreat

                                   Clarifier
                                Pretreat.

                                Clarifier

                                Product
      Slowdown

      Clarifier

      Product
  Calcium
  ™^""^"«^^^^»


  Magnesium



  Sodium
  B^MB^M.


  Potassium
  ———^-^—«.


  M-Alkalinity



 Sulfate
 ^•™-^-^™^^


 Chloride
 ™i^"^—^-«™


 Fluoride
 •—•—•^——m


 Phosphate



 Boron
 ^^•^^••^^


 Aluminum
 ^^ff^^


 Iron
 •^^^HH


 Manganese
 ^•"^•^^i^^^


 Barium
 ••^-^"^—••^


 Strontium
—™—^^.™


 Silica
mg/l
I^^^^^H


Std units
                                 5-5

                              T'30
                                                Rev. A

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                                            Tables
             Cedar Bay Expected Constituents in Sludge/Salt Produced by Treatment Unit
SUBSTANCE
CN
Sb
As
Be
Cd
Cr
Cu
Pb
Ha
Ni
Se
Ag
Zn
Tl
Phenols
Chloroform
DETECTED
no
no
yes
no
no
yes
yes
yes
no
yes
no
no
yes
no
yes
no
UNITS
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
Ib/day
PHhIHbAT
SLUDGE
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.0000
0.00
0.00
0.0000
0.00
0.00
0.00
0.00
CT B'DWN
SLUDGE
0.00
0.00
0.00
0.00
0.09
0.00
0.12
0.10
0.0000
0.07
0.00
0.0000
1.36
0.00
0.00
0.00
CRYST'L
SALT
0.89
1.49
0.89
0.15
0.06
0.45
0.29
0.29
0.0060
0.29
0.15
0.0014
3.48
0.15
3.28
0.05
TOTAL
0.89
1.49
0.89
0.15
0.15
0.45
0.41
0.39
0.0060
0.36
0.15
0.0014
4.83
0.15
3.28
0.05
NOTES
See note 6














See note 7
Notes:
 1) The concentrations are from Betz February 10,1993 data from SK clarffier effluent except for copper
 (0.015 mg/l) and silver (0.00005 mg/l) which are set at the SK discharge permit limits. There may be
 some reduction in concentration of the constituents in the SK aerated lagoons.

 2) Assumed that 500 gpm of pretreament clarifier effluent is returned to SK for use in the SK cooling
 tower and that the total flow from the SK wastewater treatment system is 9 MGD. The cooling tower
 makeup returned to SK is assumed to pass through the SK wastewater treatment system without
 removal of the constituents listed resulting  in a net increase in SK effluent concentration relative to the
 Betz data for all constituents except copper and silver.

 3) Ten cycles of concentration are assumed in the Cedar Bay cooling tower based on January 1993 SK
 effluent chemistry data.

 4) "no" in the 'Detected Column* indicates that the constituent was not detected so the actual
 concentration  in the sludge is less than the value indicated except for chloroform which was detected
 at less than the quantitation  limit.

 5) Significant variation in the actual actual concentration of the constituents in the sludge is expected
 for the following reasons:

               a) The results of only a single sample analyzed by EPA methods is available.

               b) The sample was taken at the SK clarifier. SK lagoon effluent is Cedar Bay's source
               of treated SK effluent so there is no data on the actual primary makeup water source to
               the Cedar Bay cooling tower.

               c) The concentrations of constituents in both the pretreatment and bbwdown clarifier
               feed water are too low for reliable estimation of removal.  No removal was predicted for
               the pretreatment system but some removal of suspended material and some
               copreciptation may occur.  Partial removal of some constituents is estimated in the
               bbwdown clarifier additonal constituents may be partially removed as suspended
               material and through copreciptation may also occur.

               d) The wastewater streams originating in the Cedar Bay plant (approx. 5% of total flow)
               are not included.

6) Expect a reduction in the concentration of cyanide from biological treatment and chlorination.

7) Phenols concentrations will be reduced by biological treatment.         HT ~~  o \

-------
H

-------
                                           System Description-22029-M72-LG01
                              CEDAR BAY PROJECT
                            ZERO DISCHARGE  SYSTEM
                              JOB NO.  22029-003
                             System Description
                                  for the
                  Cooling Tower Makeup Pretreatment  System
BECHTEL CORPORATION
GAITHERSBURG, MARYLAND
NO.





0
DATE





3/10/93
REVISION





Issued for use
BY






CHK'D





&*
APPROVALS





PKS





Ml

-------
                                System Description-22029-M72-LGOl
                        TABLE OF CONTENTS

                                                            Page
1.0  FUNCTION                                                 1

2.0  DESIGN BASIS                                             2

3.0  SYSTEM OPERATION                                         3

4.0  SYSTEM CONTROLS                                          4

5.0  SYSTEM COMPONENTS                                        5

6.0  UNRESOLVED MATTERS                                       6

7.0  REFERENCES                                               6
22029\Sys Desc                 ii                         Rev. 0
                             3-34

-------
                                  System Description-22029-M72-LG01

                         SYSTEM DESCRIPTION


              COOLING TOWER MAKEUP PRETREATMENT SYSTEM
 1.0  FUNCTION

 1.1  The main function of the cooling tower makeup pretreatment
 (CT Makeup Pretreatnent) system is to receive and treat the
 following streams in an Infilco Degremont Inc (IDI) DensaDeg®
 clarifier system:

      o    SK wastewater
      o    plant drain sump discharge consisting of:
           - condensate polisher drain
           - plant oil/water separator effluent
           - miscellaneous building drains
           - boiler blowdown
      o    plant storage area runoff
      o    plant sludge dewatering system filtrate
      o    neutralization tank effluent
      o    Miscellaneous zero discharge system drains
      o    Dual media pressure filter backwash

 The system is shown on P&ID M74-LG01.

 1.2  The CT Makeup Pretreatment system will satisfy the plant
 cooling tower makeup requirements during normal  and reduced load
 operation and upset conditions.   The system will also provide up
 to 500 gpm of treated water to SK for use in their cooling tower.

 1.3  An additional function of this system is to thicken the pre-
 treatment clarifier slurry and the slurry transferred from the
 cooling tower blowdown treatment clarifier.   The thickening and
 dewatering system is common to both the cooling  tower
 pretreatment and blowdown  treatment systems and  is achieved in
 the bottom portion of the  DensaDeg® clarifier.

 1.4  The lime and soda ash storage and feed systems are shared by
 both the cooling tower makeup  pretreatment and the cooling tower
 blowdown treatment systems.

 1.5  The bulk chemical storage tanks  (acid,  caustic,  and sodium
 hypochlorite)  are common to  all  systems  within the zero discharge
 system.                                                         *

 1.6   The coagulant storage tank  is used  for  the  cooling tower
makeup pretreatment  system.
22029\Sys Desc                  1    -     o_>              Rev. 0

-------
                                  System Description-22029-M72-LG01
  2.0  DESIGN BASES
  f^ii,   f *? Makeup Pretreatment system is  designed  to  treat an
  influent stream of up to 5500  gpm.   The daily  average  rate  of
  softened,  water produced is approximately  2800 gpm.

  2.2  The system is designed with the flexibility to include the
  treatment of up to 1200  gpm of stormwater.           J-ncxuae tne
    ^'    DensaDe9®  
-------
                                 System Description-22029-M72-LG01

  2.5  The  system  is designed to produce an effluent with the
  following characteristics:

  Characteristic                 Value         Units
  Calcium                       40             mg/1
  Magnesium                    50             ag/1
  Silica                        25             mg/1
  M-Alkalinity                  60             mg/1 as CaCO,
  P-Alkalinity                  40             ng/1 as CaCO,
  Suspended Solids             . 10             mg/1
  PH                            9 to 11        SU


  3.0  SYSTEM OPERATION

  3.1 Normal Operation

 The pretreatment system influent flow is pumped into a reaction
 tank which is provided with a turbine mixer and a draft tube ar-
 rangement.  In this tank, ferric chloride,  sodium hypochlorite,
 a polymer, lime slurry, and soda ash are added and combined with
 preformed solids circulated from a DensaDeg® clarifier to
 coagulate organics and suspended solids to  be settled downstream
 in the DensaDeg® clarifier.

 The reaction tank effluent flows by gravity into the pretreatment
 (DensaDeg®) clarifier,  where the suspended  and precipitated
 solids are removed.

 The softened effluent flows by  gravity from the DensaDeg®
 clarifier to the clearwell.  Sulfuric acid  is fed in the effluent
 weir of the clarifier to lower  the pH.  The pH adjusted effluent
 is pumped as needed  to the Cedar Bay cooling tower and the SK
 cooling tower.

 3.2  Storm Water  Management

 When rainwater accumulates in the  storage area  runoff basin,  the
 transfer  pumps automatically start and pump  water at a rate of
 1200  gpm  to the  Pretreatment system.  If the  turbine  generator is
 offline,  the storage  area runoff  is directed to the  emergency
 water storage tank.

 3.3 Power  Plant Wastewater Management

 Cooling tower blowdown,  plant oil/water separator effluent,
 miscellaneous building  drains, neutralization tank effluent,
 drains from the zero  discharge system, sludge dewatering
 filtrate,  and dual media filter backwash flow to  the wastewater
 holdup tank, which will  act as an  equalization  basin. Water from
 the wastewater holdup tank is pumped to pretreatment system.
22029\Sys Desc                  3    I ~ 37              Rev. 0

-------
                                System Description-22029-M72-LG01

  3.4 SK Wastewater Management
  3.5 Thickener and Sludge  Dewatering System Operation
               .                        P°rtion °f the
              reea the sludge dewatering system with
 4.0  SYSTEM P



                  SJSi^iSSr* W8ter ^ """-fnt *»


      a.   cedar Bay storage area runoff (via runoff pond)

      c!   SK was?eLte?nt Wastewater 
-------
                                   System Description-22029-M72-LG01
       o
       o
          Reaction tank pH transmitter/controller
          Clearwell pH transmitter/controller
     o    Clearwell high/low level controls
     «    £Jar*£*er inlet f low transmitter/controller
     o    Clarifler effluent turbidity


5.o  SYSTEM COMPONENTS

                    comprising the cooling tower pretreatment
       a.   Reaction tank
       b.
          •»••*»»» w*w*I kCUlll

          DensaDeg* clarifier with external sludge recirculation

          g^PSnand, rake lifting device' and accessories      °
     c.    DensaDeg* slurry pumps (dewatering system~feed pumps)
          pSmps"        system Clearwell and Clearwell transfer

     e.    Chemical feed systems:

          o     Soda ash silo,  volumetric feeder,  mixing tank,
               soda ash slurry transfer pumps (common to both
               CT  Makeup Pretreatment and CT Slowdown treatment
               systems)

          °     ii»« ?il0'  volumetric  feeder,  slurry tank,  slurry
               transfer pumps  (common to both CT  Makeup
          o     ro»m^?a«?e1?* and CT Blowdown  treatment systems)
               ™!a!^an* 
-------
                                 System Description-22029-M72-LG01

 6.0  UNRESOLVED MATTERS


 7.0  REFERENCES


           O    P&ID M74-LG01 and M74-LG02
           o    Flow diagram - Cooling Tower Makeup Pretreatment
                System
           o    Flow diagram - Cooling Tower Slowdown Treatment
                System
22029\Sys Desc                  6     J-

-------
COOLING TOWER PRETREATMENT SYSTEM
                                                                             TO SLOWDOWN
                                                                            TREATMENT SYSTEM
                                                                                                                   TO SLOWDOWN
                                                                                                                 TREATMENTSYSTEM
                                                                           TOPRECONCENTRATOR
                                                                              FEEDPUMPS
                                                                                                                              TO SLOWDOWN
                                                                                                                            TREATMENTSYSTEM
                                                       SOOWM HVPOCHLORffE I
                                                                                                                                                                TO SLOWDOWN
                                                                                                                                                              TREATMENT SYSTEM
                                                                                                                                                                FEEDPUMPS
                                                                                                                                                                      TOEVAPORATOIV
                                                                                                                                                                       CRYSTAUZER/
                                                                                                                                                                       CENTRIFUGE
                                                                                                                                                                       FEEDPUMPS
                                                                                                                                                                      TO SLOWDOWN
                                                                                                                                                                    TREATMENT SYSTEM
                                                                                                                                                                       FEEDPUMPS
 FROM EMERGENCY
WATER STORAGE TANK
                                                                                                     SLUDGE FROM
                                                                                                     SLOWDOWN
                                                                                                  TREATMENT SYSTEM
                                                                                                                                                                     PRECONCENTRATOR
                                                                                                                                                                         SYSTEM
                                                                                                                                                                       FEEDPUMPS
SKWASTEWATER J~"5
                                                                                                                                                                      TO EVAPORATOR
                                                                                                                                                                       CRYSTAUZER
                                                                                                                                                                    CENTRIFUGE SYSTEM
                                                                                                                                                                       CHEM FEEDS
                                                     TO SLOWDOWN
                                                   TREATMENT SYSTEM
                                                     REACTION TANK
                                                                                                                      (>RETREATMENT
                                                                                                                       CURFIER
                                                                                                                      (DENSADEG)
                    WASTE WOTEH
                    TRNRFR PUMPS
                                                    TOEMERSENCV
                                                 WATER STORAGE TANK
                                                                              DENSADEG
                                                                               SLUDGE
                                                                            RECmCULATION
                                                                               PUMPS
                                                                                                                                                              ,	Jrtnucoa.ua
                                                                                                                                                              I     ^ Tn^CB •&••!
                                                                                                                                                                        COOUNG TOWER
                                                                                                                                                                           MAKEUP
  NEUTRALKATKMTANK
      EFFLUENT
                                                                                                                                                            FROM SLOWDOWN TREATMENT
                                                                                                                                                                  CLEARWELL
 MHC. ZERO DISCHARGE
    SYSTEM SUMPS
                                                                                                                                                                         SK COOLING
                                                                                                                                                                       TOWER MAKEUP
                                                 TO COOUM TOWER
                                                  SLOWDOWN UNE
                              11tOOK
                           STORAGE AREA
                           RUNOFF POND
                             TRANSFER
                              PUMP
                                    i • torn
                                   YARD AREA
                                 RUNOFF POND
                                   TRANSFER
                                    PUMP
                                                                                                                                                   COOLING TOWER PRETREATMENT
                                                                                                                                                       SYSTEM FLOW DIAGRAM

-------
r -

-------
                                                  System Description-M72-LG02
                              CEDAR BAY PROJECT
                            ZERO DISCHARGE SYSTEM
                              JOB NO. 22029-003
                             System Description
                                  for the
                   Cooling Tower Slowdown Treatment System
BECHTEL CORPORATION
GAITHERSBURG, MARYLAND
               Issued for use

-------
                                 System Description-22029-M72-LG02
                         TABLE OF CONTENTS
 1.0  FUNCTION




 2.0  DESIGN BASIS




 3.0  SYSTEM OPERATION



 4.0  SYSTEM CONTROLS



 5.0  SYSTEM COMPONENTS



 6.0  UNRESOLVED MATTERS




 7.0  REFERENCES
                              Page




                                1




                                1




                                3



                                3



                                4



                                4




                                4
22029\Sys Desc
ii
                                                           Rev.  0

-------
                                 System Description-22029-M72-LG02


                         SYSTEM DESCRIPTION


              COOLING TOWER SLOWDOWN TREATMENT SYSTEM
 1.0  FUNCTION

 1.1  The main function of the cooling tower blowdown  (CT
 Slowdown) treatment system is to remove scaling and fouling
 impurities from the Cooling Tower blowdown. Yard area runoff is
 pumped into the cooling tower blowdown line. A portion of this
 cooling tower blowdown and yard area runoff combined flow is
 treated in the cooling tower blowdown treatment system and the
 remainder is used for cooling in the zero discharge system and
 returned to the cooling tower. The system is shown on P&ID
 M74-LG02.

 1.2 The desired chemistry in the system effluent is achieved by
 controlling the chemical feeds as required:

      a.   Lime and soda ash feeds are shared with the CT Makeup
           Pretreatment system, but controlled with separate
           control valves

      b.   Acid,  caustic,magnesium chloride, and sodium
           hypochlorite feeds are controlled by individual
           metering/feed pumps

 2.0 DESIGN BASIS

 2.1  Impurities  to be removed from the blowdown include  calcium,
 magnesium,  bicarbonate,  silica,.. suspended solids,, barium,  and
 organics.   These impurities must be maintained at acceptable
 levels  in the cooling tower circulating water.

 2.2  The system  is designed to treat an influent stream  of up to
 1,000 gpm in a non-scraping type accelerated rate settling tank
 (accelerator)  which is preceded by a premix/reaction tank to
 produce a softened effluent of the desired chemistry.

 2.3  The 1,000 gpm system size selected for the softening process
 will  have sufficient capacity to treat the cooling tower blowdown
 generated during normal  and reduced plant load operation,  and
 upset conditions.

 2.4   The bulk  caustic tank is shared between the cooling tower
 blowdown treatment system,  the evaporator/concentrator system,
 and the  crystallizer and centrifuge system.

 2.5  The magnesium solution system is used only for the  cooling
tower blowdown system.
22029\Sys Desc                  1     T  -M-^             Rev. 0

-------
                                 System Description-22029-M72-LG02

 2.6  The chemical feed pumps are sized to provide the required
 dosage rates under average chemistry conditions as well as under
 expected water quality excursions. Under extreme excursions,  both
 chemical feed pumps can operated to meet the chemical dosage
 requirements.

 2.7  The system is designed to treat an influent water of the
 following typical characteristics:
                      Low
 Characteristic       Value
 Calcium             150
 Magnesium           150
 Sodium              4000
 Potassium           so
 M-Alkalinity        50
 P-Alkalinity        0
 Sulfate (SO4)        3300
 Chloride            1000
 Fluoride            10
 Phosphate (PO4)      o.l
 (note l)
 Boron (B)            5
 Aluminum            o.1
 Iron                0.5
 Manganese           0.05
 Barium              0.5
 Strontium           5
 Vanadium            o.1
 Arsenic             o.S
 Silica (Sio2)        60
 PH                   7
 TOC                  200
 TSS                  50
 TDS                  6000
Typical
Value
350
300
8475
150
150
0
6800
2300
25
2
High
Value
1000
400
10,000
200
200
0
8000
3000
30
10
20
0.5
2
0.1
1
10
0.5
2
120
8
500
100
12,500
30
5
5
1
2.5
15
1
3
150
8.3
800
150
15,000
 Units
mg/1 as
mg/1 as
mg/1 as
mg/1 as
mg/1 as
mg/1 as
mg/1 as
mg/1 as
mg/1 as
mg/1 as

mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
SU
mg/1
mg/1
mg/1
                            CaC03
                            CaC03
                            CaCOj
                            CaCO3
                            CaC03
                            CaCO,
                            CaCO3
                            CaCO3
                            CaCO3
                            PO,
Note 1.   Phosphates  could be as high as  10 to 15 ppm  (as P04),
          based  on the  scale/ corrosion inhibitor selected.

Note 2.   The  low and high values are the expected ranges of each
          constituent and the actual analysis may contain some
          constituents  at the high end of the "concentration range
          and  others  at the low end of the concentration range.

2.8  The system  is designed to produce an effluent with the fol-
lowing characteristics  (to be confirmed after vendor's input):
Characteristic

Calcium
Magnesium
Suspended solids
Silica
 Value

150
50
< 10
40
     Units

     mg/1
     mg/1
     mg/1
     mg/1
22029\Sys Desc
                             Rev. 0

-------
                                 System Description-22029-M72-LG02

 3.0  SYSTEM
             tOWer ^lowdown stream is pumped to the pre-
                                                             =•

4.0  SYSTEM


22029\Sys Desc
                               3     T _a^7
                               0     -L-   T /             Rev.  0

-------
                                 System Description-22029-M72-LG02

      o    clearwell tank level transmitter
      o    clearwell high/low level controls
      o    clarifier inlet flow transmitter/controller
      o    clarifier pH transmitter/controller
      o    clarifier effluent pH transmitter/controller


 5.0  SYSTEM COMPONENTS

 The main components comprising the cooling tower blowdown treat-
 ment system are:

      a.    Premix/blowdown reaction tank
      b.    Blowdown clarifier with accessories
      c.    Blowdown sump and sump pumps
      d.    Blowdown clarifier clearwell
      e.    Chemical feed systems:

           o    Magnesium solution metering/feed pumps
           o    Acid metering/feed pumps
           o    Sodium hypochlorite metering/feed pumps
           o    Polymer storage/dilution tank  and metering/feed
                pumps
           o    Caustic metering/feed pumps
           o    Hypochlorite metering/feed pumps

 The lime and soda ash are shared with the CT  Makeup Pretreatment
 system.

 6.0  UNRESOLVED MATTERS

 7.0  REFERENCES

      o     P&ID  M74-LG01 and LG02
      o     Flow  Diagram-Cooling Tower Blowdown-Treatment  System
      o     Flow  Diagram-Cooling Tower Makeup Pretreatment System
22029\Sys Desc                  4      31 "
Rev. 0

-------
H
 i
            COOLING TOWER BLOWDQWN TREATMENT SYfiTFM
 SODIUM HYPOCHLORITE
      FEED FROM
MAKEUP PRETRTMT SYSTEM
             COOLING
          TOWER BLOWOOWN T
            (CIRC WATER   L
             SYSTEM)
          FROM PREATREATMENT
           REACTION TANK FEED
           EMERGENCY WATER
            STORAGE TANK
                        NaOd METERMQ
                            PUMPS
                                                      CAUSTIC FEED FROM
                                                    MAKEUP PRETRTMT SYSTEM


                                                      SOOA ASH FEED FROM
                                                    MAKEUP PRETRTMT SYSTEM
    LINEFEED FROM
MAKEUP PRETRTMT SYSTEM
                                    BLOWOOWN
                                     REACTION
                                       TANK
                                                                                         MAGNESIUM SOLUTION
                                                                                           METER WG PUMPS
                                                                                                     COOLING
                                                                                                     TOWER
                                                                                                    BLOWOOWN
                                                                                                    CLARFIER
                                                                                  ACID FEED FROM
                                                                              MAKEUP PRETRTMT SYSTEM
                                                                                                                         ACID METERING PUMPS
                                                                                                                              TOPRETREATMENT
                                                                                                                                  SYSTEM
                                                                                                                                (DENSADEG)
                                                                                                                                 CLARIFIER
                                                                                                                                     TOPRECONCENTRATOR/
                                                                                                                                           FILTER
                                                                                                                                         FEED PUMPS
                                                                                                                                               BECHTEL
                                                                                                                                              CEDAR BAY
                                                                                                                                       COOLINO TOWER BLOWDOWN
                                                                                                                                    TREATMENT SYSTEM FUOW OIAORAM

-------

-------
                                                  Systen Description-M72-LG03
                              CEDAR BAY PROJECT
                            ZERO DISCHARGE SYSTEM
                              JOB NO. 22029-003
                             System Description
                                  for the
                           Reverse Osmosis System
BECHTEL CORPORATION
GAITHERSBURG. MARYLAND
               Issued for use

-------
                                  System Description-22029-M72-LG03
                         TABLE OP CONTENTS
 1.0  FUNCTION




 2.0  DESIGN BASIS




 3.0  SYSTEM OPERATION



 4.0  SYSTEM CONTROLS



 5.0  SYSTEM COMPONENTS




 6.0  UNRESOLVED MATTERS



 7.0  REFERENCES
                              Page



                                1



                                1




                                3




                                4



                                5



                                5




                                5
22029\Sys Desc
ii
                                 J-52.
                                                          Rev.  0

-------
                                  System Description-22029-M72-LG03


                          SYSTEM DESCRIPTION




                        REVERSE  OSMOSIS SYSTEM
  1.0  FUNCTION
           R!V»«Sf Osmosis (R°)  system has two parts:  dual media
  filters and RO treatment.  The system is shown in P&ID M74-LG02.


  1.1  The function of the dual media filters is to reduce the
  total suspended solids (TSS)  concentrations of softened cooling

  JSSSLbl°wdown J° allow normal trouble-free operation of the RO
  system.  The system is shown on P&ID M74-LG02.


  1.2   The function of the RO system is to reduce the  total

  rilff «d S°HdS PDS)  of  the  softened  cooling tower blowdown  for
  reuse as cooling tower makeup.
 2.0  DESIGN BASES
 H^i,/0}^,?3! caPacity dual ">edia pressure filters are sized to
 handle full RO feed flow while one filter is in the backwash
 mode.
 In rJ£  5° SySt?? desi9ned for a total feed flow of 650 gpm at
 60 percent overall recovery in the 80«F to 95«F temperature
 range. The RO system feed flow capacity will drop off with
 temperature and is designed for 550 gpi feed at 65«F and 60
 percent overall recovery.


 «;3*H«n? R2 svfte» is designed to recover - from 35 to 60 percent
 rate Lf*S ***** f°r rfVse ij? the cooling tower. The recovery
 ££li    2^2  °r °Peration wiH *>e determined during operation
 based on RO feed water chemistry.  The RO units are designed for
 average 90% total dissolved solids removal.         aesxgnea ror


 2.4  The RO system is designed for uninterrupted operation. This

 iLSwaihlf ?y<.keePi?9 ?! R° System on-line during filte?
 backwashes.  A tank sized for one filter backwash is provided.
22029\Sys Desc                  1     _]__
                                                           Rev. 0

-------
                                System Description-22029-M72-LG03
2.5  Influent Water Quality

                      Low
Characteristic       Value
Calcium             100
Magnesium           10
Sodium              4000
Potassium           50
M-Alkalinity        25
P-Alkalinity        0
Sulfate  (SO4)        3000
Chloride            1000
Fluoride (Note)     10
Phosphate  (PO4)      0.1
Boron (B)           5
Aluminum            0.1
Iron                0.1
Manganese           0.05
Barium (Note)       0.5
Strontium           5
Vanadium            o.1
Arsenic             0.5
Silica (Sio2)        30
pH                  7.5
TOC (Note)          200
TSS (Note)          50
TDS                 6000
Typical
Value
200
50
8930
150
80
10
7000
2220
30
1
20
0.2
0.3
0.05
3
10
0.5
2
40
8.5
500
100
12,500
High
Value
400
100
11,050
250
200
100
8000
4000
40
3
30
0.5
0.5
0.1
5
15
1
3
50
9.5
800
150
15,000
                     Units
                    mg/1 as
                    mg/1 as
                    mg/1 as
                    mg/1 as
                    mg/1 as
                    mg/1 as
                    mg/1 as
                    mg/1 as
                    mg/1 as
                    mg/1 as
                    mg/1
                    mg/1
                    mg/1
                    mg/1
                    mg/1
                    mg/1
                    mg/1
                    mg/1
                    mg/1
                    SU
                    mg/1
                    mg/1
                    mg/1
             CaCO,
             CaCO,
             CaC03
             CaCO,
             CaCO,
             CaCO,
             CaCO,
             CaCO,
             CaCO,
             P04
Note 1.   These parameters are best estimates without the benefit
          of complete treatment elsewhere in the system.

Note 2.   Design influent water is a mixture of all streams
          except site runoff.

Note 3.   The low and high values are the expected range of each
          constituent and the actual analysis may contain some
          constituents at the high end of the concentration range
          and others at the low end of the concentration range.

2.6  The system is designed to produce an effluent with the
following characteristics (later):
Characteristic
Calcium
Magnesium
Silica
M-Alkalinity
Suspended Solids
PH
TDS
 Value
later
later
later
later
0
later
later
Units
mg/1
mg/1
mg/1
mg/1 as CaCO,
mg/1
22029\Sys Desc
        T-S4
              Rev. 0

-------
                                 System Description-22029-M72-LG03

  3.0   SYSTEM OPERATION

  3.1   Softened cooling tower blowdown  (from the blowdown
  clarifier) is pumped via preconcentrator filter feed pumps for
  treatment ,in the dual media filters and the cartridge filters and
  delivered to the RO booster pumps.

  3.2  The RO booster pumps pump the RO feedwater through the RO
  units to the RO product tank from where it is pumped via RO
  product pumps to the cooling tower basin. A portion is also sent
  for reuse in the in the zero discharge system.

  3.3  The RO brine flows under pressure to the emergency brine
  storage tank. From the emergency storage tank the RO brine is
  pumped to the evaporator feed tank by the emergency water
 transfer pumps.

 3.4  Sulfuric acid is continuously injected at the RO inlet
 header prior to the cartridge filters for pH adjustment of the
 feed stream to prevent calcium carbonate scale formation on the
 RO membranes.  Two 100% capacity positive displacement metering
 pumps take suction from the common acid storage tank.

 3.5  An antiscalant is continuously injected at the RO feed inlet
 header for additional protection against scaling of the RO
 membranes.   Two 100% capacity positive displacement metering
 pumps take suction from the antiscalant feed tank.

 3.6  Sodium hypochlorite is also continuosly injected  at the RO
 feed inlet for biofouling control.  Two 100  % capacity  positive
 displacement metering pumps take suction from the sodium
 hypochlorite storage tank.

 3.6  Flow through the RO system is  continuous,  with both RO units
 operating simultaneously in parallel under-design conditions at
 full  plant  load.   During partial load,  one  RO unit  may be
 shutdown.   The RO product will  flow to the  RO product  tank.

 3.8  The  RO product  pumps supply the dilution water to the
 antiscalant mixing tank,  the RO cleaning  system and for  RO
 membrane  flushing on shutdown.

 3.9   The  RO chemical  cleaning system is periodically used to
 clean the RO membranes by circulating  a cleaning  solution through
 the RO units and back to the RO chemical  cleaning tank.   The
 spent  solution is hauled off-site for  disposal.

 3.10 During normal operation, the RO brine will be  processed
 directly by the evaporator system (without need for storage in
 the emergency storage tank).

 3.11 A stream from the filter effluent is diverted  to a  filtered
water tank for storing filtered water for backwash. The  filter
backwash pumps take suction from this tank.


22029\Sys Desc                  3         - £&           Rev. 0

-------
                                 System Description-22029-M72-LG03

 4.0  SYSTEM CONTROLS

 4.1  The system operation will be shutoff on low level switch in
 the blowdown clarifier clearwell, or by manual initiation.
 Restart of the RO system will be manually initiated.  Out of range
 influent water chemistry (conductivity)  will be alarmed.

 4.2  The chemical metering/feed pumps will be furnished with
 electronic positioners to control suction flow based  on RO  feed
 flow.  Additional adjustments for increase or decrease in
 chemical dosage -rates will be manual.

      o    pH control will be automatic

 4.3  Initiation of the RO chemical cleaning system will be
 manual,  based on a differential pressure of the RO feed and RO
 brine or on operator's demand.

 4.4  The controls for the system will be integrated with the
 overall  zero discharge system controls.   PLCs and I/O units will
 be  furnished to interface with the zero  discharge system CRTs and
 printers.

 4.5  The following instruments are provided for local/automatic
 control  functions and monitoring of the  system:

      o    Pressure differential indication across the dual  media
           pressure filter system
      o    Pressure differential across the cartridge  filters
      o    Pressure gauges in feed,  product and brine  headers of
           each RO system
      o    Level switch on the filter backwash storage tank
      o    Flow control valve in the feed line
      o    Flow control valve in the brine line
      o    Conductivity meter in the RO product line.
      o    RO feed pH
      o    Brine conductivity
      o    Brine flow
      o    RO feed flow rate
      o    RO feed pressure  switch
      o    RO feed temperature
      o    RO feed conductivity
      o    RO feed oxidation reduction potential
22029\Sys Desc                  4                          Rev. 0

-------
                                   System Description-22029-M72-LG03
   5.0  SYSTEM COMPONENTS

   5.1  The main components comprising the RO system are:

        o    Preconcentrator/Filter feed pumps (three @ 50%) taklnr,
        o    SS^S°!L??? *lowd?™_ clarified clearwe??*' tak±"B
        o     Filtered water tank
        o     RO  cartridge filters (two @  50%)
        o     RO  booster pumps  (two @ 50%)
        o     RO  units (two @ 50%)
        o     RO  product tank
        o     RO  product pumps  (2  §100%)
            Acid meter ing/ feed pumps
                        Stofa9e tank, and metering/feed pumps
                                                        '
       o    Emergency water storage tank (1,000,000 gallons)

  6-0 UNRESOLVED MATTPPS

       o    RO product water quality
       o    RO brine water quality
  7.0 REFERENCES

       o    P&ID M74-LG01 and LG02
       o    Flow Diagram-Reverse Osmosis  Treatment System
22029\Sys Desc                   5      ~r  C H
                                            b /            Rev.  o

-------
REVERSE OSMOSIS SYSTEM
                                   ACID FEED FROM
                               COXING TOWER MAKEUP
                                PRETREATMENT SYSTEM
   NaOCI FEED FROM
COXING TOWER MAKEUP
 PRETREATMENT SYSTEM
TO RO ANTISCALANT TANK
               NaOCI METERING
                   PUMPS
                                                   ACID METERING
                                                      PUMPS
         TO COOUNG TOWER
                                          RO BYPASS
                                   TO EMERGENCY STORAGE TANK
                                                                            CARTRIDGE
                                                                              FILTER
                                                                            CARTRIDGE
                                                                              FILTER
                                              BLOWERS
                                              (2X100%)
                                                                                                                                               RO PRODUCT PUMPS
   PRECONCENTRATOR /
    FILTER FEED PUMPS
                                                         RECIRCULATON TO
                                                                                                                                              TO COOLING TOWER
                                                        CHEMICAL CLEANING
                                                                                                              CHEMICAL
                                                                                                              CLEANING
                                                                                                              FEED TO RO
                                                                                                               SYSTEM
                                                                               CHEMICAL CLEANING SKID
                             FILTER BACK
                             WASH PUMPS
           TO COOLNQ
             TOWER
                                                                                                                                                 EVAPORATOR FEED
                                                                                                                                                   STORAGE TANK
                                                                                                         TO PRETREATMENT
                                                                                                     SYSTEM REACTION TANK FEED
                                                                                                      H
                                                                              EMERGENCY WATER
                                                                               TRANSFER PUMPS
                                                                                                      TO SLOWDOWN TREATMENT
                                                                                                       SYSTEM REACTION TANK
                                                          TO WASTE WATER
                                                           HOLDUP TANK
                                                                                                                                           RE VERSE OSMOSIS
                                                                                                                                         SYSTEM FLOW DIAGRAM
                                            FILTER
                                          BACKWASH
                                            SUMP

-------
                                                  System Description-M72-LG04
                              CEDAR BAY PROJECT
                            ZERO DISCHARGE SYSTEM
                              JOB NO. 22029-003
                             System Description
                                  for the
                      Evaporator / Concentrator System
BECHTEL CORPORATION
GAITHERSBURG, MARYLAND
               Issued for use

-------
                                 System Description-22029-M72-LG04
                         TABLE OF CONTENTS
 1.0  FUNCTION




 2.0  DESIGN BASIS




 3.0  SYSTEM OPERATION




 4.0  SYSTEM CONTROLS




 5.0  SYSTEM COMPONENTS



 6.0  UNRESOLVED MATTERS



 7.0  REFERENCES
                              Page



                                1



                                1




                                2




                                4



                                5



                                5



                                5
22029\Sys Desc
ii
                                                           Rev.  0

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                                   System Description-22029-M72-LG04


                          SYSTEM DESCRIPTION




                    EVAPORATOR/CONCENTRATOR SYSTEM
  1.0  FUNCTION
           pn I?*? functions of the evaporator/concentrator system is

  as coolinf toUr\aakde-Pup0.dUCe ' distillate stream suitable for use



               function of the evaporator/concentrator system is to
               entrate  fh«  PO K^,-««  and  reduce  its    '   •La-uo
  This system is shown on P&ID M74-LG03.


  2.0  DESIGN BASTS
  a'flow ™*r2? 
-------
                                System Description-22029-M72-LG04
2.4  The  system  is designed  to  treat an  influent  water of  the
following typical characteristics:

                      Low
Characteristic       Value
Calcium             100
Magnesium           20
Sodium              8500
Potassium           100
M-Alkalinity        0
P-Alkalinity        0
Sulfate (SO4)        7000
Chloride            1700
Fluoride            20
Phosphate (PO4)      0.1
Boron (B)            10
Aluminum            0.1
Iron                0.1
Manganese           0.05
Barium              0.2
Strontium           10
Vanadium            0.4
Arsenic             1
Silica (Si02)        30
Ph                  4
TOC                 100
TSS                 0
TDS                 12000
Typical
Value
300
150
16,000
250
50
0
12,500
4100
50
0.5
35
0.5
0.3
0.1
1
20
1
3
100
5.5
500
1
23,000
High
Value
1000
250
25,0000
400
100
0
20,000
7000
70
25
50
10
3
1
5
35
3
10
150
8
800
10
35,000

Units
mg/1 as CaCO3
mg/1 as CaC03
mg/1 as CaC03
mg/1 as CaCO3
mg/1 as CaCO3
mg/1 as CaC03
mg/1 as CaC03
mg/1 as CaC03
mg/1 as CaC03
mg/1 as PO4
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
SU
mg/1
mg/1
mg/1
Note 1.   Design influent water is a mixture of all streams routed
          to the cooling tower as makeup except site runoff.

Note 2.   The low and  high  values are the expected range of  each
          constituent.  The  actual  analysis  may  contain  some
          constituents at the high end of the concentration range
          and others at the low end of the concentration range.

2.5  The condensate stream produced will meet the following water
quality requirements:

     o    dissolved solids:  less than 10 ppm, excluding organics
          and volitiles

     o    suspended solids:  none

3.0  SYSTEM OPERATION

3.1  In each of the two evaporator trains,  feedwater consisting of
RO  brine/reject and  other wastewater  from the  emergency water
storage tank is fed to the evaporator feed tank.   Sulfuric acid is
added to neutralize alkalinity.  Anti-sealant solution is added at
the tank outlet. The evaporator feed pumps convey  the feedwater to
each evaporator.
22029\Sys Desc
\
-fcZ
                                                           Rev. 0

-------
                                  System Description-22029-M72-LG04

  3.2  In each train,  the feedwater is passed through plate-type ore-
  heat  exchangers to preheat  the  feedwater  with hot  condensate
  product from the evaporator.  The cooled condensate product is sent
  to the cooling tower basin.


                     feed sjtream is conveyed to the deaerator where
                        ^         non-condensible gases are removed
  iLia,.xIn f*?1*.*^*1^' deaerator P«»PS  discharge  the deaerated and
  decarbonated brine feed to the evaporator.  The feed is mixed with
  vessel recirculation flow and a portion is evaporate"



                       *" *"* Vap0r b°dy  is Cleaned °f  Drained


            a 18 0« change  in  flow  direction from the falling  film
            heater exits  to the vapor body exit


            gravity-induced settling of droplets in the rising vapor
            flow across the vapor body area                    y


            impingement collection  of droplets  and particles  in the
            mist eliminator


            an external mesh-type entrainment separator
                         stream is  collected  and passed through a
 va            Centrffu9al compressor  where the  product stream's

 hea?erPshfnf6  "  increased to the condensing temperature of the
 thl h~L<;01np£eSSed Vap?r Stream is introduced in the shell side of
 uS it« hff; ?•«. KaPfr* ftream SWeeps throu9h the tube  bundle, giving
                   influent/recycle stream. on the other side of thl
 tubes
          ?IJ?rJfy  °- t?e  comPressed vapor  is condensed  in  the
      and S.  diAi'i? 2^* ^ ^' *„ heat< collecting in the vessel
 «..i    ^   distillate level  tank,  external to  the  evaporator
 vessel.   There,  the hot condensate  is  pumped by  the  distillate

                 th                                           11
HAL  WiJ? the rem°valof the product water vapor out of the vapor
body,  the  concentration  of dissolved  solids  left in  solution
increases precipitating additional calcium sulfate  Noraa?!y  tSe

fer su^faUcefiate £"ld PreciPitate ««t on the vessel and Cat trans^
fiLiv nf^fl^  T151S. 1S  Drevented  by maintaining a  large mass of
finely-divided calcium sulfate crystals in a slurry,  and recvclina
the slurry at high flow rates.   The large mass  of'ffnely divided

P?efe?en?iaIlvrDreSc^T; 7*"*? SitSS' Up°n Which additional sails
prererentially precipitate and crystallize out of solution.
22029\Sys Desc                  3     X'
                                                           Rev.  0

-------
                                  System Description-22029-M72-LG04


  «;1^In eaCh evaporator a recycle stream is taken from the bottom
  of the evaporator  and sent back  to the top.  A portion  is  sent

  through a separator, which removes a portion of  the  precipitated
  S£tx u •
 f^iJ  Initial  seeding is provided by adding calcium chloride to the

 3£S2\+ «.C.austl° *s added to the  evaporator to maintain  proper
 precipitating chemistry  and further  reduce scaling  within the
 evaporator  vessel.  Anti-foam  agent  solution  is  added  to the
 concentrator  to  control foaming.                    «««ea  to tne
 3.12 The  evaporator brine slurry  streams  from the separators in

 arfn™1? *r* conveve* to the crystallizer feed tank, where they
 are pumped to the crystallizer and centrifuge  system (see Crystal-
 lizer and Centrifuge System Description) .                «ys»x
 4 . 0  SYSTEM CQNTROT.g
               °P*rati°n of the evaporator system is controlled by

               inlet guide vane setting on the suction side of the

 an  «»,.P°,r^?mprlSSOr-  The guide vanes are variable pitch,
 c£ntaol  loon  l^0119^- a ?**Z f 10W Droller/vane positioner
 control  loop,  which  adjusts  the vapor  flow  rate between  the

 compressor and the  evaporator/concentrator  vessel.   This control
 loop provides for a 50% turn-down of the process.


 4.2  Overall compressor capacity is set by the operator, with the

 S2£°£   ^Slfry St°rage VOlU*e Provid^ Astern  dampening  and
 rft??«^   adjust  compressor capacity  to  respond to  changing  con-

 ftSSI;  De-nsity of tjie salt slurry f°r recycle  in the siSnp of the
 evaporator is measured and the  concentration is managed by a  flow

 r^v.?    °P throu5h  the separator,  seed  recycle tank  and  seed
 recycle pumps,  or by cascading  from a density controller.


 4.3  Excess vapor from the compressor not used for desuperheating
 or  deaerating is  vented to the  atmosphere.


 ?"! ^F1fw rate into  the evaporator/concentrator vessel is control-
 led by level  control in the vessel sump.  Flow rate into the evap-

 orator/concentrator  feed/storage  tank is controlled by tank level.

 Evaporator/concentrator pH is controlled by addition of sulfuric
 acid,  controlled  by  pH.




 4.5 The controls for the system will be integrated with the over-
 all zero discharge system  controls.
22029\Sys Desc                  4     -£ _ ^ LJ.
Rev. 0

-------
                                   System Description-22029-M72-LG04
  5.0  SYSTEM  COMPONENTS
                             °0mPrisin9 «» evaporator/concentrator
       o    Two brine evaporators
       o    TWO vapor compressors
       o    TWO concentrator recirculating pumps
       o    Two deaerators
       o    Four deaerator pumps
       o    Two trains of plate-type preheat exchangers
       o    TWO separators
       o    TWO seed/recycle tanks
       o    Two seed recycle pumps
       o     Two distillate tanks
       o     Four distillate transfer pumps
       o     one evaporator feed  tank
 6.0 UNRESOLVED MATTERS

 7.0 REFERENCES
           O    P&ID M74-LG03 & LG04
           o    Flow diagram - Evaporator/Concentrator System
                Flow diagram - Crystallizer/Centrifuge System
o
22029\Sys Desc                  5     "X
                                3            -^            Rev.  0

-------

-------
                                                 System Description-M72-LG05
                              CEDAR BAY  PROJECT
                            ZERO DISCHARGE SYSTEM
                              JOB NO.  22029-003
                             System Description
                                  for the
                      Crystalizer and Centrifuge System
BECHTEL CORPORATION
GAITHERSBURG, MARYLAND
NO.





0
DATE





3/10/93
REVISION





Issued for use
BY





W~
CHK'D





56*
APPROVALS





ff*





to

-------
                                  System Description-22029-M72-LG05
                         TABLE OF CONTENTS
 1.0  FUNCTION



 2.0  DESIGN BASIS




 3.0  SYSTEM OPERATION




 4.0  SYSTEM CONTROLS




 5.0  SYSTEM COMPONENTS




 6.0  UNRESOLVED MATTERS



 7.0  REFERENCES
                              Page



                                1



                                1




                                1




                                2




                                2



                                3




                                3
22029\Sys Desc
ii
                                                           Rev.  0

-------
                                  System Description-22029-M72-LG05
       o    TWO crystallizer feed pumps
       o    one slurry storage tank with agitator
       o    Two slurry transfer pumps
       o    one centrifuge
       o    Two hotwell transfer pumps
       o    Desuperheating station
       o    Thermocompressor
 6.0 UNRESOLVED MATTERS
       o    Crystallizer feed  and slurry concentration
       o    Feed and product flow
       o    Power and steam  use
 7.0
      O    P&ID M74-LG03 and LG04
      o    Flow Diagram-Crystallizer/Centrifuge System
22029\Sys Desc                  3       J- ~ M            Rev.  0

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      COOLNQ WATER FROM
  COOLING TOWER SLOWDOWN LINE
                                                                                                                                                    TO
                                                                                                                                                ATMOSPHERE
   -vj
    THAN-A"
EVAPORATOR BRINE
    TRAWB-
EVAPORATOR BRINE

                                                                                                                                                   U
               __».. . __
               ^E|DTAM<
CRYSTALLIZER
FEED PUMPS (2)
                                                                                                                                                    BECHTEL
                                                                                                                                                    CEDAR BAY
                                                                                                                                          CRYSTALLIZER / CENTRIFUGE S YSTr *
                                                                                                                                                   FLOW DIAGRAM
                                                                                                                                          JOiNd  IpwaHa
                                                                                                                                                             RIV.

-------
                                 System Description-22029-M72-LG05

                         SYSTEM DESCRIPTION


                CRYSTALLIZER AND CENTRIFUGE SYSTEM
 1.0  FUNCTION
 1.1  The function of the crystallizer and centrifuge system is to
 receive the  brine  from the  two  evaporator  trains and  produce
 condensate-guality water for use as cooling tower makeup.

 1.2  Another function of this system is to concentrate  or  dewater
 the remaining solids in the crystallizer slurry with a  centrifuge
 to produce a near-dry waste for off-site disposal.

 The system is shown on P&ID M74-LG04.


 2.0  DESIGN BASIS

 2.1  The  single-train  crystallizer  and  centrifuge  system   is
 designed to treat a concentrator brine  slurry from the two evapora-
 tor trains at a design flow of 50  gpm.

 2.2  The crystallizer  is  designed to produce  distillate-quality
 condensate for return to the cooling towers, and a salt slurry.

 2.3  The centrifuge is designed to produce a near-dry  (10 to  15%
 design  moisture content)  salt crystal  cake.  The extracted liquid
 and remaining dissolved solids  are returned to the  crystallizer
 feed tank.
3.0  SYSTEM  OPERATION          . ., .

3.1  The crystallizer portion of the system is designed to concen-
trate the salt slurry from the evaporator system to a higher  % salt
slurry.  The crystallizer slurry is then pumped to a centrifuge,
where most of the remaining free liquid is removed, leaving a dry
salt cake.

3.2  The  crystallizer  process  commences  with  evaporator  waste
slurry combining with centrifuge centrate return in the agitated
crystallizer feed tank,  and being  fed to the suction side of the
crystallizer recirculating pump by the crystallizer feed pumps.

3.3  The recirculating  pump circulates  the combined feed and re-
cycle stream through a steam heated heat exchanger and the crystal-
lizer vapor  body.   This crystallizer stream,  or liquor,  picks up
heat from  the heat exchanger,  and  enters the vapor body  of the
crystallizer  and  flashes due  to  the  vacuum  produced  by  the
barometric condenser.
22029\Sys Desc                  1       X ~ &°            Rev. 0

-------
                                System Description-22029-M72-LG05
3.4  The steam used for heating the crystallizer feed liauor in 1-ho
               °°»  af te/ivin
    £ cSSSHF °°yy»? af tegiving  p its ht ,  and    p
  the crystallizer hotwell via the steam condensate trans f
                            ^^
                                                          punped to
                                                          S0%
                                    of the "Dining free  water and
 4.0  SYSTEM CONTPnj.g
 4.1  Vendor standard controls.
     .
                                       be lntegratea
 5.0  SYSTEM COMPONENTS
             n Components c°»Prising the crystallizer and centrifuge
      o    one crystallizer vapor body: with internal mist
           entrainment separator
      o    one crystallizer heat exchanger
      o    one crystallizer recirculating pump
      o    One vacuum pump
      o    one vacuum pump vent  condenser
      o    One barometric  condenser  with  hotwell
      o    Two steam  condensate  transfer  pumps
      o    one crystallizer feed tank with agitator
22029\Sys  Desc                  2

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         APPENDIX J

    EXECUTIVE SUMMARY
AIR QUALITY IMPACTS ANALYSIS

-------

-------
                                                                              EN&
                                EXECUTIVE SUMMARY
The objective of the information presented in this document is to  provide data  useful for
assessing:

     1)  whether, on balance, the air pollutant emissions and air quality impacts of the Cedar Bay
        Cogeneration Project (CBCP), as proposed to be modified, and the addition of the three
        new proposed package boilers scheduled for the Seminole Kraft Corporation (SKC) site
        necessary to provide 640,000 Ib. of steam per hour for SKC's use, will be less than the
        emissions and air quality impacts of  the future SKC recycling operation, providing
        640,000 Ib. of steam per hour for SKC's use without the CBCP.

     2)  whether, on balance, the permitted air pollutant emissions  and  air quality impacts of the
        CBCP, as proposed to be modified, andthe addition of the three new proposed package
        boilers scheduled for the SKC  site at their permitted capacity, will be less than the
        emissions and air quality impacts of the CBCP as certified;

     3)  whether, on balance, the permitted air pollutant emissions and  air quality impacts of the
        CBCP, as proposed to be modified, and the addition of the three new proposed package
        boilers scheduled for the SKC  site at their permitted capacity,  will be less than the
        emissions and air quality impacts of the future SKC recycling operation at permitted
        capacity without the power plant;

     4)  whether the CBCP,  as proposed to be  modified, would either  cause or contribute to a
        violation of an ambient air quality standard (AAQS) or cause or contribute to a violation
        of the allowable Prevention  of Significant Deterioration (PSD) increments, in either the
        region surrounding the facility (a PSD  Class II  area) or the two distant PSD Class I
        areas.   The two PSD Class I areas are the Okefenokee  and  Wolf  Island Wilderness
        areas in Georgia.   In addition,  information is  presented to  provide data useful for
        assessing whether the CBCP would produce air toxics concentrations above the  Draft
        Florida No Threat Levels (NTLs);

    5)  whether  the CBCP,  as  proposed  to be  modified, would induce significant indirect
        pollutant emissions as result of directly related growth, create adverse impacts on soils,
        vegetation or  visibility, and whether the cooling tower  vapor plume  would cause
        significant fogging or icing on nearby transportation routes; and
r:\pubs\proiects\S402027\8S1.ES                       ES-1                                February. 1993
                                     CM

-------
      6)  updated information on air emission controls and.emission rates. The lower air pollutant
          emission rates for the CBCP CFB boilers, and the inclusion of a new add-on technology
          (selective non-catalytic reduction) may require some changes to the original conditions
          of certification and air permit.  To provide the State and EPA with accurate and updated
          mformat.on on the project for review of the proposed changes, ENSR, on behalf of U S
          Generating Company, developed a technical review of  the air emission controls and
          emission rates.

 The "CBCP as certified" refers to the facility as described in the Final Order and Power Plant Site
 Hertifirat nn DA oo ox j-*	i i-_i	*^  J__.    .                          «"<-•  icuiioue
                                                                                     e
™P PA88'24DdatedFeb^11' 1991 ^ the March 28, 1991 Final Determination  y
the
           P         D                                      ,                         y
           Permit No. PSD-FL-137. The "CBCP as proposed to be modified" refers to the fading
 as descnbed ,n the Amended Petition for Modification of Certification filed with the Division of
 Admm.strat.ve Hearings on July 22, 1992, plus further improvements proposed by the CBCP.

 The "future SKC Recycling Operation without the power plant" refers to the two bark and three
 0,1-f.red boilers presently at the SKC site as they could be operated should the CBCP not be  In
  h,s hypothetical future case, without the CBCP, it is ENSR's understanding that the exhausts of
 the three power boilers would be combined and exhausted through a newly constructed 125-foot
 stack to lessen susceptibility to aerodynamic downwash effects caused by nearby structures.

 The "addition of the three new proposed package boilers scheduled for the SKC site necessary
 to provide the 640,000 lb of steam for SKC's use" refers to three package boilers proposed by
 SKC capable of  producing a total of 375,000 Ib/hr of steam.  For purposes of the technical
 3fln nnn5,;'/? T^ ** ** ^'^ ^ Steam re'uirement is me< ^ the CBCP supplying
 380,000 Ib/hr and the SKC package boilers supplying  260,000 Ib/hr.

 The "addition of the three new proposed  package boilers scheduled for the.SKC  site at their
 perm.tted capacity" refers  to these same boilers producing a total of 375,000 Ib/hr of steam.

 The proposed SKC package boilers will be capable of accommodating either fuel oil or natural
 gas.  Not yet permrtted, these boilers will, according to the SKC permit application fire  No 2
 distillate fuel  oil with a maximum sulfur content of 0.5% and an annual average sulfur content of
 0.3 /o.

 In making the assessments for pollutant emissions, the maximum annual emissions of health
 cntena  pollutants,  other  regulated  pollutants, and non-regulated  air toxics  pollutants  are
 compared. To compare the air quality impacts, evaluate compliance with the AAQS and PSD
 increments, compare the air quality impacts to the draft NTLs, evaluate soils, vegetation and
r.\pubs\pro|«cts\S402027\8S1.ES                       ES-2
                                                                             February. 1993
                                    3-Z

-------
 	   EN;R

 visibility impacts, and characterize cooling tower impacts, comprehensive atmospheric dispersion
 modeling was performed in accordance with EPA and Florida DER Guidelines.

 Table ES-1 illustrates the difference in annual pollutant emissions  between CBCP as proposed
 to be modified plus the SKC package boilers, and the future SKC recycling operation (both cases
 at 640,000 Ib/hr steam usage by SKC). This table demonstrates the decreases or increases in
 the actual annual emissions of four categories of pollutants by operating the CBCP and the SKC
 package boilers and shutting down the SKC power and bark boilers. The health criteria and PSD
 increment pollutants  are those for which ambient air quality standards or PSD increments have
 been established. The total regulated pollutants include  the criteria  and all PSD  regulatory
 pollutants. Non-regulated air toxics represent twenty different compounds emitted by the sources
 in question which are included in the list of 751 compounds cited in Florida's Draft Air Toxics
 Permitting Strategy.  In aggregating health criteria, PSD increment and regulated pollutants, TSP
 and PM-10 are treated as individual pollutants exclusive of one another, although PM-10 are a
 portion of TSP.  Because PM-10 and TSP are also treated exclusively when comparing ambient
 impacts (the health criteria standards address PM-10 while the PSD increments  address TSP),
 the emissions comparisons treats them as different pollutants for consistency with the standards
 and PSD  increments.

 The comparisons of annual emissions shown in Table ES-1 assume that the SKC package  boilers
 always fire fuel oil. To the extent that they fire natural gas on an annual basis, the decreases in
 emissions would be greater.  As shown in Table ES-1  decreases in air pollutant emissions are
 achieved by the CBCP, as proposed to be modified, in each category, except non-regulated air
 toxics.

 A comparison of air quality impacts between  the CBCP, as proposed to be modified plus the SKC
 package boilers, and  the SKC recycling operation without the CBCP (both cases at 640,000 Ib/hr
 steam usage by SKC) is summarized in Table ES-2. The table summarizes the changes  due to
 the CBCP as proposed to be modified and the SKC package boilers for each criteria pollutant as
 well as total air toxics. Three values are listed for each pollutant: 1) the change to the maximum
 predicted  concentration  of the pollutant anywhere (higher,  lower or insignificant maximum
 concentration); 2) the net effect on air quality on a regional basis in terms of the highest predicted
 pollutant concentrations (improved, insignificant, or degraded); and 3) the percent of locations for
 which modeling was performed which showed a net benefit in terms of the highest concentrations.
 A total of 1008 locations, referred to as "model receptors," were addressed. The majority of these
 fall within 10 kilometers of the CBCP, but a portion  extend as far as 25 kilometers. As shown in
 Table ES-2, the CBCP as proposed to be modified and the SKC package boilers result  in  either
 lower or insignificant maximum concentrations of all criteria pollutants  and total air toxics, a net
n\put>sVproiectS\S402027\8S1.ES                       ES'3

                                    J-3

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                                    TABLE ES-1

            CBCP as Proposed to be Modified Plus SKC Package Boilers
                                        vs.
                                  SKC Recycling
                    (Both Cases at 640,000 Ib/hr Steam for SKC)
                     Net Change in Annual Emissions Due To
                     CBCP and SKC Package Boilers Firing Oil
                         Pollutants Category

                 Health Criteria and PSD Increments
                 Total Regulated
                 Total Non-Regulated Air Toxics
                 Total Pollutants
   Net Change
   =====
Decrease 343 tons
	•—•	
Decrease 594 tons
Increase 29 tons
                                                  Decrease 565 tons
R: 'VS:-:'.;ft.i7EC-rr\S40i027\a51 .EJT
                                      ES-4

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                          TABLE ES-2

     CBCP as Proposed to be Modified Plus SKC Package Boilers
                              vs.
                         SKC Recycling
                (Both Cases at 640,000 Ib/hr Steam)
Air Quality Changes Due to CBCP Plus SKC Package Boilers Firing Oil(a)
Pollutant
3-hour SO2
24-hour SO2
Annual SO2
24-hour PM-10
Annual PM-10
1-hour CO
8-hour CO
Annual NO2
Monthly Pb
Annual Pb
8-hour Air Toxics
24-hour Air Toxics
Annual Air Toxics
Maximum
Concentration
Lower
Lower
Lower
Lower
Higher
Insignificant
Insignificant
Lower
Insignificant
Insignificant
Lower
Lower
Net Regional
Air Quality
Effect
Percent of
Locations with
Air Quality Benefit
Improved ! 97.6
Improved
Improved
Improved
Insignificant
Insignificant
Insignificant
Improved
Insignificant
Insignificant
Improved
Improved
Lower | Improved
98.2
99.5
98.2
91.4
Not applicable
Not applicable
99.6
Not applicable
Not applicable
99.6
99.6
99.6
     (a|See Section 2
                              ES-5
                            CT-S

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 	EN3*

 improvement or insignificant change in the highest concentrations on a regional basis, and a net
 air quality benefit at virtually all locations.

 A summary of the comparison of the maximum permitted annual pollutant emissions between
 CBCP as certified and  CBCP as proposed to be modified plus the  SKC  package boilers is
 presented in Table ES-3. This table illustrates the decrease in emissions resulting from CBCP
 as proposed to be modified plus the SKC package boilers for the four pollutant categories.  As
 shown in the table, decreases are achieved in all categories of pollutants except non-regulated
 air toxics, which don't change.

 A summary of the differences  in air quality  impacts at permitted capacity between CBCP as
 certified and CBCP as proposed to be modified plus the SKC package boilers is presented in
 Table ES-4. Lower or insignificant maximum concentrations are shown to result from Cedar Bay
 as proposed to be modified for most pollutants with the exception of SO2. However, the net effect
 on highest SO2 concentrations is insignificant on a regional basis. Impacts of CO are insignificant
 in each case, so a meaningful comparison capnot be made.  Annual average PM-10 impacts,
 although lower in terms of the maximum concentrations,  are not significantly affected on a
 regional basis  with a small  number of locations experiencing a benefit.  Although there is an
 average  improvement, the magnitude of the  improvement is not significant.

 Table ES-5a summarizes the comparison of maximum  permitted emissions between CBCP as
 proposed to be modified plus the SKC package boilers, and the SKC recycling operation. This
 table shows an increase in each of the four pollutant categories.  However, these changes do not
 account for substantial additional decreases that are associated with the shutdown of recovery
 boilers, lime kilns and smelt dissolving tanks at SKC as a result of SKC converting to a recycling
 operation.

 According to the PSD  permit application for the SKC package boilers, substantial decreases in
 baseline emissions will be achieved.  These are listed in Table ES-5b. As shown in the table,
the overall  result is a  net decrease in the  first three pollutant categories. Decreases in non-
 regulated air toxics were not  estimated for  the application, but  these would also offset  the
increases shown in Table ES-5a at least to some extent.

 Notwithstanding the above calculated emission increases, as shown in Table ES-6, maximum
pollutant concentrations are lower or insignificant for the CBCP as proposed to  be modified.  In
addition, for the individual pollutants, either a net regional air quality benefit or an insignificant
change results and the vast majority of locations experience a benefit with the CBCP as proposed
to be modified, compared to the SKC recycling operation.
                                        ES-6                                February ,9g3

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                     TABLE ES-3

CBCP as Certified vs. CBCP as Proposed to be Modified Plus
                 SKC Package Boilers
     Net Change in Permitted Annual Emissions Due to
CBCP as Proposed to be Modified Plus SKC Package Boilers
Pollutants Category
Health Criteria and PSD Increments
Total Regulated
Total Non Regulated Air Toxics
Total Pollutants
Net Change
Decrease 2,099 tons
Decrease 3,51 9 tons
No Change
Decrease 3,51 9 tons
                        ES-7

-------
                             TABLE ES-4
    CBCP as Certified vs. CBCP as Proposed to be Modified Plus SKC
                           Package Boilers
          Air Quality Changes Due to CBCP as Proposed to be
             Modified Plus SKC Package Boilers Firing Oil(a)
Pollutant
3-hour SO2
24-hour SO2
Annual SO2
24-hour PM-10
Annual PM-10
1 -hour CO
8-hour CO
Annual NO2
Monthly Pb
Annual Pb
8-hour Air Toxics
24-hour Air Toxics
Annual Air Toxics
Maximum
Concentration
Higher
Higher
Lower
Lower
Lower
Insignificant
Insignificant
Lower
Insignificant
Insignificant
Lower
Lower
Lower
Net Regional
Air Quality
Effect
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Insignificant
Improved
Improved
Improved
Percent of
Locations with
Air Quality Benefit
80.1
73.6
45.6
64.8
30.6
Not Applicable
Not Applicable
44.2
Not Applicable
Not Applicable
95.6
95.6
95.4
       ""See Section 2
'JrC-. PP.'.vJECTr\5402027\851.ETT
                                 ES-8

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                            TABLE ES-5a
CBCP as Proposed to be Modified Plus SKC Package Boilers vs. SKC Recycling
             Net Change in Permitted Annual Emissions Due to
    CBCP as Proposed to be Modified Plus SKC Package Boilers Firing Oil
Pollutants Category
Health Criteria and PSD Increments
Total Regulated
Total Non Regulated Air Toxics
Total Pollutants
Net Change
Increase 270 tons
Increase 20 tons
Increase 36 tons
Increase 56 tons
                            TABLE ES-5b

          Net Changes Due To Additional Sources Shutting Down00
               at SKC for Conversion to Recycling Operation
Pollutants Category
Health Criteria and PSD Increments
Total Regulated
Net Change
Decrease 4,668
tons
Decrease 4,712
tons
Combined Net Change
with CBCP
Decrease 4,398 tons
Decrease 4,692 tons
'"Recovery Boilers, Lime Kilns, Smelt Dissolving Tanks
                                ES-9

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                                      TABLE ES-6



            CBCP as Proposed to be Modified Plus SKC Package Boilers

                                 at Permitted Capacity

                                          vs.

                         SKC Recycling at Permitted Capacity

           A.r Quality Changes Due to CBCP Plus SKC Package Boilers'"
                                             Net Regional

                                              Air Quality

                                                Effect
                                                  Percent of

                                                Locations with

                                              Air Quality Benefit
                     Maximum

                   Concentration
    Pollutant
    ==

3-hour SO
                                              Improved
                                              ~


                                              Improved
                                                     _


                                              Improved
24-hour SO
            24-hour PM-10
            — •


            Annual PM-10
                     Higher
                          n


                   Insignificant
                                                            Not Applicable
                               Insignificant


                                 Lower
                                 Insignificant
                                        -


                                  Improved
                                                Not Applicable
Annual NO2



Monthly Pb
—


Annual Pb
                               Insignificant
                               —


                               Insignificant


                                 Lower
                                               Not Applicable
                                               Not Applicable


                                                   99.6
8-hour Air Toxics
                                  Improved



                                  Improved
                                  •


                                  Improved
           24-hour Air Toxics
           Annual Air Toxics


           '"See Section 2
ft: \PURS'.PR.VTErTr\S402C27 v651.Err
                                        ES-10

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 	EhKR


 Table ES-7 summarizes the results of the modeling for compliance with  AAQS  and PSD
 increments and for comparison to the Draft Air Toxics NTLs. For the applicable AAQS and PSD
 increment pollutants, the predicted compliance status is listed.  "Compliance" indicates that an
 evaluation  of  all  major sources  in Duval  County  in addition to Cedar Bay  demonstrates
 compliance with the standard. "Insignificant Impacts" indicates that no evaluation of the standard
 was performed since Cedar Bay impacts were insignificant. "Does not cause or contribute to a
 violation" indicates that all major sources in Duval County were modeled but only those total
 concentrations to which the Cedar Bay facility contributed a significant concentration were
 evaluated, and those concentrations were predicted to be below the standards.  As shown in the
 table, the predicted compliance status for each criteria pollutant and standard is favorable.  For
 the draft No Threat  Levels,  the CBCP, as  proposed to  be modified  complies with all NTLs
 examined.  Some compounds have NTLs for more than one averaging period.

 As demonstrated  by the foregoing summary and further documented herein, the Cedar Bay
 Cogeneration Project as proposed to be modified, plus the new proposed SKC package boilers
 on balance, in terms of pollutant emissions and'air quality,  result in lower environmental impacts
 than  either the SKC recycling operation or the  Cedar Bay facility as originally certified.   In
 addition, the Cedar Bay Cogeneration Project, as proposed to be modified, will comply with all
 applicable ambient air quality standards and prevention of significant deterioration increments,
 neither causing nor contributing to  a violation.

 The results of additional analyses conducted further indicate that:

     1)   No additional significant emissions and thus no additional significant air quality impacts
         will result from any growth directly related to the CBCP of a residential, commercial or
         industrial  nature,

    2)   No adverse impacts on soils or vegetation will occur due  to the CBCP,  in either the
         region surrounding the CBCP, other nearby sensitive areas, or the distant PSD Class
         I wilderness areas, and

    3)   No significant affects of the cooling tower on fogging or icing of local transportation
         routes or salt deposition in the area surrounding the CBCP will  occur.
r:\pubs^pro|«cls\S402027\8S1.ES                      ES-1 1
                                                                             February. 1993

-------
                      TABLE ES-7
             CBCP as Proposed to be Modified
Compliance with Ambient Air Quality Standards (AAQS) and PSD
              Increments, and Comparison to
           Draft Air Toxics No Threat Levels (NTLs)
Pollutant
S02
PM-10
TSP
CO
N02
Pb
Air Toxics
Standard
AAQS
PSD Class II
PSD Class I
AAQS
PSD Class II
PSD Class I
AAQS
AAQS
PSD Class II
PSD Class I
AAQS
Draft NTL's
Predicted Compliance Status
Does Not Cause or Contribute to a Violation
Does Not Cause or Contribute to a Violation
Compliance
Does Not Cause or Contribute to a Violation
Compliance
Compliance
Insignificant Impacts
Does Not Cause or Contribute to a Violation .
Does Not Cause or Contribute to a Violation
Compliance
Insignificant Impacts
Compliance
                         ES-12
                       3"-

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          APPENDIX K

     EXECUTIVE SUMMARY
COMPARATIVE HUMAN HEALTH AND
  ECOLOGICAL RISK ASSESSMENT

-------

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                                                           	        EN3R
                                                           ————_^_^__

                               ES.O EXECUTIVE SUMMARY
  ES.1    Introduction
  The Cedar Bay Cogeneration Project (CBCP), is currently under construction at the Seminole
  Kraft Corporation (SKC) recycling facility located  in Jacksonville, Florida. The CBCP includes 3
  coal-fired circulating fluidized bed (CFB) boilers, capable of generating 250 MW of electricity and
  supplying SKC with steam, and two limestone dryers fired with No. 2 fuel oil.

  In order to supply SKC with 640,000 Ib/hr of steam, CBCP would have to be augmented with 3
  package boilers that would be owned and operated by SKC. CBCP plus these package boilers
  would replace 3 oil-fired (No. 6) power boilers and  2 bark boilers currently being operated by SKC
  and which would have to be operated if the CBCP and package boilers were not completed.
                                           •
  ENSR performed a comparative human health  and ecological risk assessment to ascertain
  whether the CBCP plus the package boilers operating at nominal  capacity to produce 640 000
  Ib/hr of steam would have, on balance, less environmental impact than the current SKC Recycling
  Operation driven by the existing bark and power boilers without  the CBCP and the package
  boilers.  The following two  cases were used in the assessment:

  (A) Emissions from the CBCP plus 3 package boilers expected to be required at the SKC site
     to supplement steam delivery.  The package boilers were assumed to be fired with No 2 oil
     with an average annual sulfur content of  0.3%.  As the package boilers may actually use
     natural gas, this assumption should provide a high estimate of metals emissions.  For this
     assessment, emissions were calculated for the" "average" operation of  the plant, i.e., the
     CBCP operated at 85.5%  capacity required to deliver enough electricity to the power'grid
     consistent with the economic incentives in its  power supply contract and  steam at a rate of
     380,000 Ib/hr to SKC and 260,000 Ib/hr from the  package boilers.

 (B)  Emissions from the SKC Recycling Operation  as  it would be configured without CBCP and
     the new package boilers, delivering steam at  640,000 Ib/hr.  This includes 3 power boilers
     fueled w,th No. 6 oil, and 2 bark boilers with  1,000,000 gal/yr  No. 6 oil and the remainder
     bark,  a reasonable configuration for a long term assessment, given the historical operating
     conditions of these units.
R:\PUBS\PROJECTS\5402027\510.ES                   ES-1
                                                                              March. 1993

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                                  	EN.-R
  ES.2    Methods

      ES.2.1   Human Health Risk Assessment

  In assessing potential human health risks, ENSR followed the four step protocol recommended
  by the National Research Council (NAS, 1983), as follows:

     •   Hazard Identification,
         Dose-Response Assessment,
     •   Exposure Assessment, and
     •   Risk Characterization.

         ES.2.1.1    Hazard Identification: Specifying the Substances to Analyze

 The first step in the hazard identification process is to determine the  quantity  and  nature of
 chemicals potentially released  from a source: The next step is to identify those substances
 whose nsk to human health should be assessed.  The criteria  used for the identification are the
 tenacity of the constituents, and  their persistence and/or mobility in the environment.

 For step one, the chemicals considered  for inclusion  in the CBCP  plus package boiler risk
 assessment were those appraised in the air quality analysis of the CBCP (ENSR 1993)  This
 list is comprised of five criteria pollutants and 26 other organic and inorganic substances that are
 included on the Draft Florida Air Toxics list.

 Based on the relative toxicity and persistence  of these listed substances,  ENSR selected 10
 metals, the polynuclear  aromatic hydrocarbons (PAH), formaldehyde  and radionuclides  for
 inclusion in the health risk assessment of the CBCP and package boilers.

 The metals were selected because they have relatively high toxicity and are persistent in the
 env.ronment, allowing for accumulation.  Therefore, these inorganic elements have the greatest
 potential to produce health or ecological risk from combustion sources.  PAH. some of which are
 considered by EPA to be probable carcinogens, were selected based on their toxicity,  although
 they tend to be less persistent than the metals.

 Although formaldehyde is  not  typically found to produce significant  risks from fossil fuel
 combustion sources,  this compound was selected because it has been included in an inhalation
 nsk assessment that was part of a draft U.S. EPA  Environmental Impact  Study (EIS) of. the
 CBCP (Dames and Moore, 1992). Similarly, the draft EIS included radionuclides in its health risk
 assessment; therefore, ENSR included radionuclides in the  present risk assessment
R:\PUBSVPROJECTS\5402027\510.ES                '   ES-2
                                        C° ^                                 March, 1993
                                          -2.

-------
                                                                              ENR
                                                                     	^mi^m^mm
  The same substances were used in the risk assessment of the existing SKC boilers  with two
  exceptions. First, radionuclides were not analyzed for this source because emissions of these
  substances are so much lower from oil fired units including the SKC power boilers.  Second
  chlorinated dioxins and furans were included among the substances analyzed for SKC,  because
  bark burners are reported to emit these compounds (Sassenrath, 1991).

  These list of compounds assessed are shown in Table ES-1.

         ES.2.1.2    Dose-Response Assessment

  The dose-response assessment defines the relationship between the  dose or intake of a
  substance and the likelihood that a health effect (e.g., cancer or other effects) will occur There
  are different dose-response relationships defined for exposure by the oral route (e.g., ingestion
  of soil, fish, or other foods) and for exposure by inhalation. The outcome of the dose-response
  assessment, when coupled with  assumptions regarding the magnitude  of human exposure
  provides a numerical estimate of potential risk..

  ENSR used cancer dose-response information derived by the U.S. EPA for each of the chemicals
  assessed that are regarded by EPA as known or probable human carcinogens, with the exception
  of lead.  Lead is considered a probable human carcinogen, but U.S. EPA has yet to develop a
  cancer dose-response value for this element.

 An assumption used by U.S. EPA and other regulatory authorities for compounds with known or
 potential carcinogenic effects is that there is no threshold for effect.  That is, there is some level
 of risk associated with every dose above zero.  The U.S. EPA's Human Health Assessment
 Group  has  developed  computerized  models  that  extrapolate   observed  dose-response
 relationships to the low dose levels encountered in environmental situations. The mathematical
 models assume no threshold and  use human and/or animal dose-response data to develop a
 potency estimate for a compound.  In extrapolating the results of animal experiments  to humans
 an assumption is made that man is more sensitive to the effects than the experimental animal'
 The mathematical models assume that carcinogenic dose-response is linear at low doses and
 most calculate the 95%  upper bound on the range of possible dose-response slopes  This value
 is known as a cancer slope factor (CSF). The use  of these assumptions makes it more likely
 than not that cancer risk estimated using the CSF overestimates true risk.

R:\PU8S\PROJECTS\5402027\510.ES                    ES-3
                                                                             March. 1993

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                                                                             EKR
                                     TABLE ES-1

                             Chemicals Assessed in the
                               Health Risk Assessment
           Antimony
           Arsenic
           Barium
           Beryllium
           Cadmium
           Chromium (hexavalent)
           Lead
           Mercury
           Nickel
           Carcinogenic Polynuclear Aromatic Hydrocarbons (PAH)
           Vanadium
           Formaldehyde
           Total Radionuclides (CBCP only)
           Chlorinated dioxins and furans (existing SKC only)
R:\PUBS\PROJECTS\S402027\510.EST
                                     ES-4
                                     Ic-f
March, 1993

-------
  Because of the linearity assumption, simply multiplying the CSF by the estimated dose provides
  an estimate of extra cancer risk specific to the conditions of exposure.

  ENSR used  Reference Doses derived by the U.S. EPA to assess the potential effects of
  substances that are not carcinogenic.  For compounds with known or potential effects other than
  cancer, it is assumed that there exists a dose below which no adverse health effects are likely
  to occur. This dose is described as a "threshold".  An approximation of a threshold dose — the
  dose at which no effects occur — may be observed in animal experiments or observations in
  accidentally exposed humans.  This dose level is called a No Observed Adverse Effect Level
  (NOAEL).   To account for the uncertainty that.such a NOAEL can be applied to a large human
  population  that may contain particularly sensitive individuals, U.S. EPA and other regulatory
  authorities  divide NOAEL values by "uncertainty factors." By applying such uncertainty factors
  U.S. EPA derives a Reference Dose (RfD) that represents a dose below which it is extremely
  unlikely that even sensitive subgroups of a population would suffer toxic effects (U.S. EPA,  1991).
  Less sensitive members of the population would be protected to an  even greater extent.   To
 determine the potential  impact of a noncarcinogenic chemical, the estimated dose is divided by
 the RfD to arrive at what U.S. EPA refers to as a "hazard quotient." A hazard quotient of one or
 less indicates an adequate certainty that a toxic effect will not be observed.

         ES.2.1.3     Exposure Assessment

 Exposure assessment involves determination of the ways  people might be  expected  to  be
 exposed to  source emissions and estimation of the extent of potential human  exposure  to the
 chemicals assessed. To accomplish the latter in this risk assessment, "exposure scenarios" were
 constructed, in which the behaviors of people that promote exposure (e.g., their inhalation rates,
 frequency of contact with soil, type and amount of .food eaten) were quantified to aid in  calculating
 the total exposure to chemicals  that might occur.

 Ambient air  concentrations of chemicals for each potential exposure pathway were modeled using
 the U.S. EPA model ISC2.  In order to conduct such modeling, estimates of the emissions from
 the CBCP  and  SKC  Package  Boilers and the existing SKC  boilers  were required.  These
 emissions were then subjected to  air dispersion and wet and dry deposition  modeling.  Air
 dispersion models provided an estimate of ambient air concentrations of the chemicals assessed
 at locations  of interest.  The deposition models, which provided estimates of the rate at which
 chemicals assessed reach the ground surface, were subsequently used to determine  the extent
to which chemicals enter surface soil, surface water, and foodstuffs (fish  and vegetables) that
people might consume.  This approach is shown schematically in Figure ES-1.
R:\PUBS\PROJECTS\S402027\510.ES                    ES-5
                                         C0 °                                 March. 1993

                                       K-5

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                                                                                OCR
                             Emissions Estimates
       Air Dispersion
         Modelling
              Deposition
              Modelling
                        Deposition and
                      Runoff into Surface
                            Water
    J
                                        1
   Deposition onto
Leafy Vegetables and
    Root Uptake
                                            Deposition and Mixing
                                                   in Soil
  Ambient Air
 Concentration
             Vegetable
            Concentration
Fish Concentration
                                             Soil Concentration
                                                                     Ingestion and
                                                                   Dermal Absorption
Consumption
                                   Total Exposure
                                     FIGURE ES-1
                                  Exposure Assessment
U920000
                                        ES-6
                                       fc-t

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                                                                               ENS
                                                                           	—•—^—^—^
  Exposure to chemicals emitted into the air can occur via both direct and indirect pathways  The
  direct pathway for chemicals emitted to the air is  inhalation of particle-bound  and gaseous
  chemicals. As previously discussed, particulate-bound chemicals will deposit onto land and water
  surfaces and may distribute from those media to foodstuffs.  People may be exposed indirectly
  by contacting or ingesting deposited materials.

  While the direct exposure pathway, inhalation, is relevant to exposure assessment for almost any
  facility, the indirect pathways are determined by the nature of the area surrounding the facility
  In the case of CBCP, potentially exposed individuals in the surrounding area reside in single
  family houses, suggesting that children may have play areas near their residences. There are
  a very limited number of commercial vegetable and fruit operations in the County, but the low
  density of homes in the vicinity of CBCP suggests that it is reasonable to assume backyard
  gardens  exist.  Since Jacksonville is a seaboard community and  is  located on an  extensive
  estuarine river system, consumption of  locally caught fish  is  another pathway of relevance
 Therefore, for locations near residences, the applicable and  relevant exposure pathways were
 considered to be:
                                            •

     •   inhalation
         inadvertent ingestion of and dermal contact with soil.
     •   ingestion of home-grown produce; and
         ingestion of fish.

 Exposure estimates were made for a hypothetical Reasonably Maximally Exposed individual who
 for the purposes of this assessment, was assumed  to be located at  points in residential or
 res.dentially-2oned areas where air dispersion and/or deposition modeling indicated the greatest
 impact. Th,s approach provided the highest realistic estimate of exposure hence the terminology
  Reasonably Maximally Exposed," or RME. Exposures to receptors at other locations were also
 estimated, to provide perspective  on the spatial distribution of potential exposures and the
 consequent health risks in the area surrounding the facility.

 The RME based on maximum ambient air concentrations would reside along August Drive
 northwest of the Dames Point and Dames Point Manor areas of Jacksonville. Although there is
 industnal development in this area, there are also single family residences. Points of maximum
 depos,t,on occurred in different locations than the points of maximum air concentration because
 wet deposition modeling assumptions are less dependent on stack parameters than the dispersion
 assumptions, making the magnitude of deposition rate essentially a function of distance from the
source. Therefore, another RME was selected as being the nearest residential property to the
CBCP.  Th.s location is at the southern end of Cedar Bay Road, approximately 500 meters to the
west northwest of CBCP. Two additional "near residential" locations were selected  One of these
R:\PUBSVPROJECTS\S402027\510.ES                    ES-7
                                                                              March. 1993

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 	ENCK

 is the Polly Town area of Jacksonville, to the north northeast of the site, and the other is the
 northernmost portion of Arlington, due south of CBCP.

 Potential  health  risks to sensitive receptors in  the area surrounding the facility were  also
 evaluated.  Sensitive receptors may include  children in playgrounds or schools, the elderly in
 nursing homes, or the ill in health care facilities such as hospitals. For the present health risk
 assessment, schools and  playgrounds were  selected as locations for  sensitive  receptors
 surrounding the facility. These included the San Mateo Little League field on Kraft Road, to the
 north of the site, the San Mateo School, to the northwest, Almadale Christian School, to the west,
 Panama Park in downtown  Jacksonville,  and  the Fort Caroline School in Arlington.

 The locations of these receptors are shown in Figure ES-2.

        ES.2.1.4    Risk Characterization

 Risk characterization involves estimating the magnitude of the human health risks associated with
 exposure to the chemicals assessed.  In this step, the results of the exposure assessment were
 combined with the dose-response assessment to estimate the potential risks to human health.
 This resulted in a quantitative estimate of the likelihood that an individual will experience  any
 adverse health effects given the specific exposure assumptions made. Estimates of health risks
 were generated for both potential carcinogenic and noncarcinogenic effects associated with each
 substance assessed. A summary of risks is presented in Section ES.3.

    ES.2.2  Ecological Risk Assessment

 An ecological risk assessment has also been performed for the two sets of emission sources.
 The ecological assessment consists of the characterization of the-area surrounding the CBCP,
 the development of a Conceptual Site Model (CSM) to identify the important taxonomic/functional
 groups  of  the  ecosystem  that may  utilize  ecologically  important  local  habitats,  and  the
 identification  of  critical  exposure  pathways  of  potentially emitted  chemicals  to  these
 taxonomic/functional groups.  Based on site-specific information, an aquatic evaluation and a
 terrestrial evaluation were performed and are  presented as separate analyses in Section ES.3.

        ES.2.2.1     Conceptual Site Model

The ecosystems surrounding the CBCP contain important terrestrial, aquatic, and riparian habitats
 (Figure ES-3). Species that are likely to be found there were identified based on site visits and/or
published information. Following the habitat and species characterization, chemicals assessed
were identified.  Finally, the primary exposure pathways for chemicals emitted into the
H:\PUBSVPHOJECTS\5402027\510.ES                    ES'8
                                                                                   1993

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     U.S.G.S. 7.5 minute series quadrangle of
     Jacksonville, Florida

     Legend:	_^_

       • Residential Location

       • Parks and Schools
       .5
      rs
     Scale m Miles
      0   .5    1
Scale In Kilometers
                                                       ES-2
                                               Receptor Locations
M930039
                                                                                                           March, 1993

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                                                                                                          EKR
      U.S.G.S. 7.5 minute series quadrangle of
      Jacksonville, Florida

      Legend:	

         •J& Aquatic Habitat

         R Riparian Habitat

        T*» Terrestrial/Habitat (Wooded)

        Tm Terrestrial/Habitat (Wetland or Marah)
     Scale In Miles
      0
Scale in Kilometers
                                                       ES-3
                               Ecological Habitat in the Vicinity of the CBCP Site
M930O4S
                                                                                                         FWxuuy, 1993

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                                                                              EM3R

  environment were identified as potential consumption of fish by piscivorous birds and mammals,
  and consumption of worms by terrestrial mammals.

  After identifying the habitat, chemicals, and pathways within a project area, the CSM was used
  to select "representative" species.  Representative species  are those which best represent a
  major taxonomic group within the area or, because of their functional biology, have relatively high
  potential exposure to chemicals assessed.  The snowy egret (Egretta thula). belted  kingfisher
  (Ceryje alcvon),  eastern mole (Scaloous aquaticus).  and river otter (Lutra canadensis) were
  chosen as representative species for these habitats.

         ES.2.2.2    Dose-Response

  In this assessment, dose-response values are taken from federal criteria, when available and
 when  not available are derived from a review of the literature. Ambient Water Quality Criteria
 (AWQCs) have been derived for both  fresh  and salt surface waters for many of the chemicals
 emitted by the CBCP and package boilers and the existing SKC boilers.  For those chemicals
 assessed without AWQCs, the lowest observed  effects level for chronic  effects found  in the
 literature were used to develop benchmark concentrations.  For the mammalian and avian species
 evaluated in this assessment, the procedure used by the  U.S. EPA to derive human oral
 reference doses  is used to develop the  oral dose-response values.  Much of the  available
 literature has been  summarized by the Agency for Toxic Substances and Disease Registry for
 mammalian species and by the  U.S.  Fish and Wildlife Service for avian species.  These
 summaries included the laboratory species and studies, and the lowest chronic NOAEL in the
 summary of literature is considered an appropriate dose-response value.

         ES.2.2.3    Mammalian and Avian Exposure Assessment

 The assumptions that were used to predict potential exposure of representative species are
 presented below. For each representative species, exposure  pathways are determined and a
 lifetime  average  daily dose is  calculated  using species-specific parameters.  All of the
 representative species are assumed to reside in the vicinity of the CBCP throughout their lifespan.
 It is further assumed that these representative species obtain all their food (e.g.,fish) and water
 requirements from the Broward River or from a location of maximum potential deposition  from the
 two sets of  emissions  sources.  Exposure  pathways  were  developed for each of the
 representative species.
R:\PUBS\PROJECTS\5402027\S10.ES                   FS-11
                                                                             March. 1993
                                       k-

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        ES.2.2.4    Ecological Risk Characterization

Risk characterization involves estimating the magnitude of the potential for an adverse ecological
effect associated with exposure  to  the  chemicals assessed.  For  the  aquatic  analysis a
comparison of the predicted surface water concentrations in the St. Johns and Broward Rivers
was made to federal aquatic marine chronic criteria.

For the analysis of the pptential for adverse effects for terrestrial species, ratios are calculated
in a manner parallel to the calculation of human hazard quotients. The exposure dose for each
individual chemical  assessed is divided  by the appropriate dose-response value to  derive a
hazard quotient. The level of ecological concern for noncarcinogenic hazard quotient is defined
by the criteria established by the U.S.  EPA (1988).  Conclusions are expressed as  "no concern"
if the ratio for each chemical assessed is equal to or less than 0.1; "possible concern" if the ratio
falls within the range of 0.1 and 10; and "high concern" if the ratio is equal to or greater than 10.

ES.3    Summary of Results

    ES.3.1   Human Health Risk Assessment

Many conservative assumptions were used in the risk assessment steps, including modeling of
air, soil, and water concentrations, exposure frequencies, and intake rates for  most of the
exposure pathways.  U.S. EPA dose-response values are derived employing  conservative
assumptions  and are  intended  to  account  for sensitive individuals  including  children on
playgrounds.  Given this methodology, actual risk levels for the "average" individual are likely to
be much lower than those predicted here.

The health risk assessment was conducted, for.locations where a-reasonable maximum exposure
(RME) might  occur,  as well  as other locations in the vicinity of the CBCP.

As shown  in Table ES-2, the human health risk  assessment indicates that all  cancer risks
associated  with exposure to emissions from the two sets of sources are less than 1 in 100,000,
risks that U.S. EPA  has found to be acceptable in a similar regulatory setting.  There was only
one location of the 9 analyzed where  the cancer risk from the CBCP and package boilers was
greater than that for the SKC bark and power boilers.  Cancer risks at other locations are 50%
or more lower for CBCP plus package boilers  than  for the existing SKC boilers.

It is apparent from the extra cancer risk levels reported at other locations that the risk decreases
with distance from the site or with less intense exposure  patterns.
R:\PUBS\PROJECTS\S402027\S 10.ES                   ES-12                                  March. 1993

                                        fc-IZ.

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                                                                 ENSl
                               TABLE ES-2
            Cancer Risk Comparisons of CBCP and SKC Emissions
Location
Dames Point Manor
Cedar Bay Road
Polly Town
Arlington
Kraft Rd. Ballfield
San Mateo Elementary
Schooi
Almadale
Christian School
Panama Park
Ft. Caroline Elementary
School
Exposures
Inhalation
Soil
Foodchain
Inhalation
Soil
Foodchain
Inhalation
Soil
Foodchain
Inhalation
Soil
Foodchain
Inhalation
Soil
Inhalation
Soil
Inhalation
Soil
Inhalation
Soil
Inhalation
Soil
Cancer Risk
(Chances in 100,000)
CBCP and
Package
Boilers
0.05
0.24
0.03
0.02
0.05
a.oa - -
0.03
0.03
0.01
SKC
Existing
0.14
0.16
0.1
0.08
0.10
0.10 "-'
0.09
0.08
0.04

Difference
in Risk
CBCP-SKC
-0.09
+0.08
-0.02
-0.06
-0.05
-0.07
-0.06
-0.05
-0.03
R:\PUBSVPROJECTS\5402027\510.EST
                                    ES-13
March. 1993

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 Neither facility has significant impact on other health outcomes, as measured by comparison to
 RfDs.  As shown in Table ES-3 Hazard Indices were well below one for both sets of emissions
 sources at all locations.  This indicates that it would be extremely unlikely that any toxic effect
 would result from exposures to chemicals from either facility.  The hazard indices for the SKC
 Bark & -d Power Boilers are smaller than those for CBCP and package boiler at two locations, but
 the re erse is true at 5 other locations and at the remaining 2 locations the Hazard Indices were
 approximately equal.

 Thus, overall, neither the existing SKC boilers nor CBCP plus package boilers can be expected
 to have an impact on the human health of the surrounding community.

     ES.3.2  Ecological Risk Assessment

 Characterization of potential impacts to aquatic species is  performed by comparing predicted
 incremental concentrations  to ambient water  quality criteria.  For all of the.chemicals, the
 predicted surface water concentrations from emissions of the CBCP and package boilers are less
 than  one percent of the chronic criteria. Indeed, the predicted surface water concentrations of
 most chemicals range from about one hundredth to less than one ten thousandth of a percent of
 the criteria.  Thus, the predicted surface water concentrations due to emissions of the CBCP and
 package boilers meet the established chronic criteria by a large margin.

 The characterization of potential impacts to terrestrial and avian representative species was
 performed by computing a hazard quotient (the ratio of the predicted intake in a species to a
 benchmark intake expected to have minimal effect).  The hazard quotients for all the chemicals
 for all the representative species potentially affected by the CBCP and package boilers are equal
 to or below 0.1. These ratios are classified by U.S. EPA as "no concern" (U.S. EPA, 1988). This
 analysis indicates that the representative species will hot be adversely impacted by the chemicals
 assessed emitted by the CBCP and package boilers.  Because these representative species are
 potentially more highly  exposed  and are used as indicators for the other mammalian and avian
 species in the area, the analysis indicates no potential for adverse effects exists in those species
 either.

 As with the CBCP and package boilers,  the potential  affects of all chemicals  emitted  by the
 existing SKC bark and power boilers on river otters, snowy egrets and belted  kingfishers are
 classified as "no concern" by the U.S. EPA. In addition, the potential effects of all  chemicals, with
the exception  of vanadium, on eastern  moles at two receptor locations, 675 and 901 are also
classified as "no concern" by the U.S. EPA. The SKC vanadium emissions are classified as being
of "potential concern" for the eastern mole at Receptors 675 and 901. Because of the
R:\PUBS\PROJ£CTS\5402027\510.ES                   ES'14                                 ,. _K 100,
                                                                               MauCn, 1993

                                        K-if

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                               TABLE ES-3

                Comparisons of Potential Non-Cancer Impacts
                        of CBCP and SKC Emissions
Location
Dames Point Manor
Cedar Bay Road
Polly Town
Arlington
Kraft Rd. Ballfield
San Mateo Elementary
School
Almadale
Christian School
Panama Park
Ft. Caroline Elementary
School
Exposures
Inhalation
Soil
Foodchain
Inhalation
Soil
Foodchain
Inhalation
Soil
Foodchain
Inhalation
Soil
Foodchain
Inhalation
Soil
Inhalation
Soil
Inhalation
Soil
Inhalation
Soil
Inhalation
Soil
Hazard Index
CBCP and
Package
Boilers
0.02
0.1
0.02
0.02
0.03
0.002
0.002
0.002
0.0008
SKC
Existing
0.03
0.05
0.02
0.01
0.03
0.009
0.008
0.007
0.004
Ratio of
CBCP
SKC
0.7
2.0
1.0
2.0
1.0
0.2
0.3
0.3
0.2
R:\PUBS\PROJECTS\5402027\S 10.EST
ES-15
                                                                     March, 1993

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 	EM3I

 conservative assumptions used in the risk assessment, it. is not likely that the vanadium emitted
 from existing SKC sources will result in observable adverse ecological affects to the eastern mole.

 ES.4    Conclusions

 The findings of this risk assessment indicate that operation of the CBCP and package boilers will
 have a negligible impact on human health. By replacing SKC's bark and power boilers, the CBCP
 and package boilers may actually provide some net health benefit, because the cancer risks from
 the CBCP and package boilers are less than those of the SKC facility as it now exists.

 The findings of the ecological risk assessment indicate that the CBCP will not pose a potential
 ecological risk to the aquatic or terrestrial environments. The potential effects of CBCP emission
 of all the chemicals on all the species examined are classified as "no concern".  The vanadium
 emissions from  the existing  SKC boilers are classified as being of "potential concern" for the
 eastern mole at Receptors 675 and 901. Thus, the CBCP and package boilers may be expected
 to present less ecological risk for the locations, species, and chemicals assumed than the existina
 SKC boilers.
R:\PUBSVPROJECTS\S402027\510.ES                   ES-16                                 Ma,^ 19g3

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         APPENDIX L

    FLORIDA DEPARTMENT
OF ENVIRONMENTAL REGULATION
 CORRESPONDENCE REGARDING
    LIME MUD COMPOSITION

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      Florida Department of Environmental Regulation

      TWln Tbweis Office Bldg. • 2600 Blair Stone Road • Tallahassee, Florida 32399-240O
           _...  _                                      Carol M. Btownec, icerenry
       Uwton Chiles, Governor
                         March 28,  1991
Julia Blunden
D*v«lopmont Manager
ASS Cedar Bay, Inc.
1001 North 19th Street
Arlington, Virginia  22209

Dear Julie:

     Our Hazardous Waste Section has reviewed the
supplemental information supplied by you regarding the lime
mud deposits at the AES Cedar Bay Cogeneration Project Site
in Duval County,  Florida.  They have concluded that these
deposits do not constitute a hazardous waste so long as the
water content of  the lime mud is less than 50%.

     The Department agrees that AES Cedar Bay, Inc. has
complied with condition IX of the Conditions of
certification and may relocate the lime mud deposits as
described  in the  SCA and Erosion sediment Control Plan.

     If you have  any further questions please contact me.

                         Sine*
                          Steve Palmer, P.E.
                          Siting  Engineer
                          Division of Air Resources
                            Management
 SP/ah
                              L-l

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7-1

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           APPENDIX M

    TEVfUCUAN ECOLOGICAL &
 HISTORIC PRESERVE INFORMATION
FROM THE NATIONAL PARK SERVICE'S
    AGENCY BRIEFING BOOKLET

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                         APPENDIX M

                     INFORMATION ON THE

           TIMOCUAN ECOLOGICAL & HISTORIC PRESERVE

From - the National Park Service's "agency briefing booklet'
                                      October 1991
       Note:   Only portions  of  the  "agency briefing booklet"
       dealing with the  "Preserve Purpose  and Significance"
       are provided in this  Appendix.  The cover  letter  from
       the National Park Service is provided for  context and
       as a reference.   Maps are not easily  reproduce-able and
       so are  not  provided.

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   •\
              United States Department of the Interior

                         NATIONAL PARK SERVICE

                      FORT CAROLINE NATIONAL MEMORIAL
IN REPLY REFER TO:           TIMUCUAN ECOLOGICAL & HISTORIC PRESERVE

    D18 (TIMU-S)             12713 Fort Caroline Road
                       JACKSONVILLE. FLORIDA 32225 - 1299

    October 1, 1991


    Mr. Greer Tidwell, Regional Administrator
    U.S. Environmental Protection Agency
    345 Courtland Street, Northeast
    Atlanta, Georgia  30365

    Dear Mr. Tidwell:







   P?es2^J1VS?l ^ inoludes .Fort  Caroline National Memorial?  ?Ee

   l*f^i%?™0^:^^^^^
   federal  levels.  The National Park Service  (ms] has  ilentifiel
                       OWnerShiP' ^wardship a'nd^o'r jurisdSat
                        resource management within  the preserve
   P^otef
                                                             t
                    '

      rScinaitenc
  representatives of the NFS Southeast Regional  off ice  in At
NFS
              i^^^aSis^
              your participation.  We have scheduled 9a mee?rng in

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             please
 Suzanne  Lewis   /
.Superintendent

 Attachment

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agency briefing booklet
         October 1991
    TIMUCUAN
ECOLOGICAL AND HISTORIC PRESERVE
          FLORIDA

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                              CONTENTS


FOUNDATION FOR MANAGEMENT 1
    PRESERVE PURPOSE AND SIGNIFICANCE 1
        A Vision for Timucuan 1
        Purpose Statements 2
       . Significance Statements 2
        Interpretive Themes 3
    PRESERVE EXISTING CONDITIONS 4

INTRODUCTION TO ALTERNATIVES 9
    GIVENS/IMPLICATIONS OF EXISTING CONDITIONS  9
    GOALS FOR ALTERNATIVES 9
        Natural Resource Management 9
        Cultural Resource Management  10
        Visitor Experience 10
        Recreation 11
    PLANNING NEEDS  11
                                   •
                                   *

QUESTIONNAIRE/MATRIX/METHODOLOGY CHART 12
                                MAPS
Natural Resources 5
Known Cultural Resources
Recreational Resources  7
Landownership 8
                                 Hi
                                IV fc

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                        FOUNDATION FOR MANAGEMENT
 PRESERVE PURPOSE AND SIGNIFICANCE

 A Vision for Timucuan

 Timucuan Ecological and Historic Preserve contains some 46,000 acres, most of which are
 wetlands. The preserve's enabling legislation also identified eight cultural resources worthy
 of interpretation. All  but three of these  resources are nonextant, and  except  for the
 Zephaniah Kingsley Plantation, most are related to the continuum of fortification of the
 Lower St. Johns River area.

 Historically the lower St. Johns River was a very important resource-^-the seat of political,
 military, and religious power of Spanish Florida. This continuum of defense-related activity
 is evident today with the presence of the U.S. Navy's facility at Mayport.

 The historic fortifications of the preserve have little meaning by themselves, and must be
 related to the bigger picture of European, and later American, occupation of Florida and the
 many struggles to keep it. The story of settlement, economic development, and exploitation
 (both subsistence and commercial) is intertwined with the story of political, military, and
 religious life in the region.

 Although the 46,000 acres that currently encompass the preserve do not make up the entire
 wetlands ecosystem of the St. Johns River, their designation by Congress  as a preserve,
 coupled with the recent rise in American consciousness towards preservation and protection
 of wetlands, makes them a valuable natural resource. Visitors would have opportunities to
 learn and experience the natural resources of the preserve on their own terms, which will in
 part help make clear the experiences of those who fought for, and settled, lived, and continue
 to live there.

 Timucuan Ecological and Historical Preserve is two resources worthy of preservation and
 interpretation—a magnificent and dynamic wetland with its attendant ecosystem, and an
 area  that  possesses a significant and important  cultural history.  Together, these  two
 resources  form a fabric that is richer and more diverse  than either of its two separate
 threads. A careful interweaving of these respective components will emphasize the totality
 of the wetlands/cultural experience and present an informational and educational experience
 for park visitors.

The area should be managed as the dynamic natural/cultural system that it is. The Timucuan
experience should be both water and land based to provide visitors multiple opportunities to
enjoy the natural and cultural resources. Providing visitors access by water would allow a
better understanding of both the ecology of the wetlands and their past and present human
use.

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Purpose Statements


The purpose of the Timucuan Ecological and Historic Preserve is to


   •  Protect, preserve,  and interpret the fresh- and salt-water wetlands  and uoland

      St"S s       "" 6nCOmpaSSed between *• ». Johns and Nassaurive^td
                 system
       Protect  preserve, and/or interpret the prehistoric and  historic  sites  features
       remnants and events related to human use and occupation of the St JoSsTd
       Nassau rivers and estuarine system.
    •  Provide for water- and land-based recreation that sustains natural and cultural
                                                                           »•>" •.«*€»*
       resource values.



 Significance Statements


 The preserve encompasses a magnificent and dynamic wetland with its attendant ecosystem
 that covers a large  relatively unimpaired afea within the Jacksonville city liSS Tto
 preserve is a rich and diverse biological community that contains


    •  an important habitat used by rare and sensitive species such as the bald eagle
       Atlantic loggerhead turtle, West Indian manatee, and wood stork


    •  a remnant of productive salt marsh once prevalent along the Atlantic Coast


    •  the scarce, undeveloped coastal upland communities, such as the maritime hammocks


    •  natural vistas and expansive views of and across waterways, salt marshes, and upland
       communities in an urban setting                                       upwna


The preserve contains representative examples of prehistoric and historic activities spanning

iSuS"T   OCCUpati°nV ^P^n exploration, cultural contact, conflict, fortification, and
settlement m a river and estuarine environment. The most significant representations include


    •  prehistoric sites  illustrating some of the oldest  and longest  periods of human
      habitation in southeastern United States


    •  Fort Caroline National  Memorial,  commemorating the  first  French-Protestant
      settlement in the New World


   •  San Juan del Puerto, a mission representing European attempts to control native
      American populations


   •  the Kingsley Plantation, the southernmost example of a sea island plantation
                                        2

                                    W-g

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  The preserve provides the setting for stories of significant historical interest related to
  Fort Do T  ° °f the. St J°^ RiV6r Vall6y' SUCh M Forts San GabrieSsan Stain
  ™   Ri £eQrmana*' forts.at St. Johns Bluff and Fort George Island, Thomas Creek  St'
  Johns Bluff Spanish-American War fortification, and Yellow Bluff Fort State nLtoric Site
                    rhere "" V?macular landscapes and structures that exemplify "Old
                   hfeways, such as fish camps.

 The  preserve provides a large  open area of waterways and uplands for recreational
 opportumties-e.g, boating, fishing, hiking, bicycling, primitive camping      recreatl°nal
 Interpretive Themes
 At Timucuan there is an opportunity for harmony to exist between human use and

 S? ^ ^S hTry a£lCtS the * *** Water «uaH* «** the overalUcenic quahty
 TVie loetfands are a dynamic eco^sfem that provide the interface between land and
 water This ecosystem serves as an environmental indicator because it istas'ly disrupted
 Sood° oUnt10ni°r ^ dls^rbances. Wetiands provide atmospheric stabilization, ero oTand
 ?h, w^a  }    gr°un|dwater ™h**ee, and remove pollution and toxins frorn sedimente
 toZ%   *   f™**5    ,dmg End SpaWnlng eemm^a f°r fish ^ birds> Deluding thoS
 threatened and endangered  species; a wildlife refuge; and a  nursery for  shellfish The
 wetlands also provide a buffer from storms.                              sneunsn.  Ine
    Zou,er 5f  Johns River has historically been and remains a strategic waterway

sLT? FZ   I?"  l°Hdr?' The rfVer WaS f°rtified by several
Spanish British and Americans Confederates         -
 Spanish British and Americans, Confederates and Union-in attempts to control the interior
 access. Several military conflicts occurred in thelower St. Johns .Ri^r-systSniS^Z
 bpamsh and French, and combatants in the American Revolution at Thomas Creek Physical
 reminders of the military presence along the river  includes military haTdware Tnd
 fortification m the form of gun emplacements and earthworks. The continuing legacy of the
 rivers military significance is the modern U.S. Navy installation at Maypor"

 Various peoples through time have relied on the resources of the lower St Johns
 River for basic subsistence. The daily survival of other prehistoric and historicp«mlesw^
 lived along  the river  was affected by the  available natural resources  Agriculture was
 practiced in several forms along the river-the Timucuan slash-and-bum Sques and

 dedttel to St±£r? Way'fit0 ^ 6Stablishment of **mal P^taSSTST^
 Sifi^V  the production of specific crops. The river  and wetlands offered fishine and
 shellfish harvesting, conducted by all groups to the modern day-an evolution from the
Timucuan midden piles to the present-day Buddy's  Fish Camp. The  rivlr^ed as both
transportation barrier  and access corridor.                             served as both

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M-10

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        APPENDIX N

     FLORIDA DIVISION
  OF HISTORIC RESOURCES
CORRESPONDENCE REGARDING
    CULTURAL RESOURCE
    ASSESSMENT REQUEST

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 June 21,  1990
 Heinz Mueller
 EIS Project Officer
 U.S. EPA,  Region IV
 345 Courtland St., N.E.
 Atlanta, Georgia  30365
                                                  JUN 2 9
                     FLORIDA DEPARTMENT OF STATE

                                Jim Smith
                               Secretary of State
                      DIVISION OF HISTORICAL RESOURCES
                               R.A. Gray Building
                               500 South Bronough
                           Tallahassee, Florida 32399-0250
                       Director's Office    Telecopier Number (FAX)
                         (904) 488-1480      (904) 488-3353
                                         In Reply Refer To:
                                         Susan M.  Henef ield-Herring
                                         Historic Sites Specialist
                                         (904)  487-2333
                                         Project  File No. 901649
 RE:  Cultural Resource Assessment Request
      EPA/EIS FDER State Analysis Report Draft
      Cedar Bay Cogeneration Project, Jacksonville
      Duval County, Florida

 Dear Mr. Mueller:

 In accordance with the procedures contained in  36 C.F.R., Part
 800 ("Protection of Historic Properties"), we have reviewed the
 above referenced project(s)  for possible impact to archaeological
 and historical sites or properties listed, or eligible for
 listing, in the National Register of Historic Places.   The
 authority for this procedure is the National Historic
 Preservation Act of 1966 (Public Law 89-665), as  amended.

 We have reviewed the above referenced draft environmental impact
 statement and find it  to be  complete and sufficient.   Thus it is
 the opinion of this agency that project activities will have no
 effect on any archaeological or historic sites  or properties
 listed,  or eligible for  listing,  in the National  Register of
 Historic Places,  or otherwise of national,  state,  regional,  or
 local  significance.   The project is consistent  with the historic
 preservation aspects of  Florida's coastal zone  program,  and  may
 proceed without further  involvement with this agency.

 If  you  have any questions  concerning our comments,  please do not
hesitate to contact us.  Your interest in protecting Florida's
archaeological  and historic  resources is appreciated.
                               Sincerely,
                                          jp.  -^L
GWP/smh
cc:  Hamilton S
Archaeological Research
   (904)487-2299
                  Oven
                                      W.  Percy,  Director
                               Division  of Historical Resources
                                            and
                               State Historic Preservation Officer
                           M-l
Florida Folklife Programs
    (904)397-2192
                                    Historic Preservation
                                      (904)487-2333
                                                   Museum of Florida History
                                                       (904)488-1484

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       APPENDIX O



BASICS OF SOUND AMD NOISE

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                 Source:  Anon (modified by EPA)
2.2 BASICS OF SOUND AND NOISE


Sound is a complex vibration transmitted through the air that, upon
reaching  the  ears, may  be perceived  as desirable  or  unwanted.
Noise  can  be  defined  simply  as  unwanted   sound  or,  more
specifically,  as  any  sound  that  is  undesirable  because  it
interferes with  speech and hearing, is  intense enough  to damage
hearing, or is otherwise annoying (EPA 1978).

The human ear's ability to hear sound depends upon the frequencies
present; we hear best the frequencies present in speech, generally
1000 Hz  to  4000  Hz,  and less well the  frequencies  outside this
range.   In  order to measure sounds in a way that corresponds to
human  perception, various weighting  factors  are  applied  to the
levels  of sound in  specific  frequency intervals and  added or
subtracted based on the  average human response to sounds in that
frequency range; the resultant values  are then summed to determine
the overall  "weighted" level.  The most commonly used weighting
systems  are  the  "A"  and "C"  scales.   The  A-scale de-emphasizes
primarily the low-frequency portion of  the sound spectrum.   A-
weighting provides  a good  approximation of the response  of the
average  human ear and correlates well with the average person's
judgment of the  relative loudness of a noise event.  Sound levels
using the A-scale frequently are denoted by dB(A); more properly,
however, the unit is  dB and the context should make it clear that
the sound level  is A-weighted.

Sound  waves propagate  away from  a noise  source  and  the sound
intensity decreases with increasing distance from the source due to
the spreading of the sound energy over  an  increasing area.   The
sound intensity  varies inversely with the square of distance from
the source.   For each time the distance from the source doubles,
the sound pressure is reduced  by  a factor of  two and  the sound
intensity is reduced by a factor of  four.  This  is  equivalent to a
decrease  of  approximately 6 dB in sound pressure  level for each
doubling  of  distance  (spherical  spreading).    In  addition to
spherical spreading, atmospheric absorption and phenomena,  such as
wind and temperature  gradients,  also affect the  propagation of
sound through the air.  Sound propagating from  sources on or near
the ground  (such as  aircraft ground runups  and  flight  at low
altitudes)  is   also   influenced  by  terrain,  vegetation,  and
structures which may either absorb or reflect sound, depending upon
their characteristics,  location,  and  orientation relative to the
source (FICON 1992).

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2.3 NOISE METRICS

To assess the impacts of sound on a diverse spectrum of receptors,
a variety  of metrics  (quantitative noise  measures) may be used.
Depending  on  the  specific  situation,  appropriate  metrics  may
include single event or cumulative metrics.  Single event metrics
are  used to  characterize a  specific noise  event;  they  do  not
describe the overall noise environment.  Single event metrics are
used to assess the potential impacts of sound on structures and may
be employed  for  informational  purposes in the assessment of some
human effects, such as sleep disturbance and speech interference.
Cumulative metrics take  into  account the  sound  levels  of  all
individual events  that occur during a  specified period
(e.g., one hour, 24 hours, etc.)  and the number of  times those
events occur.  Cumulative metrics are most useful in characterizing
the overall noise  environment and( are  the primary metrics used in
development  of  community dose-response  relationships.    Common
metrics used to  characterize a  single  sound event include Mavinmm
A-Weighted Sound Level and Sound Exposure Level.

Maximum A-Weighted Sound Level  (iy	)

The single event maximum sound level metric (L^*) is the highest A-
weighted sound level measured  during  an event.   It  is  a useful
metric for comparing the  loudness  of different noise events,  and
for  estimating  whether  or  not  an  event will   interfere  with
conversation  or sleep. At common voice levels and outdoor talking
distance (about 1 meter apart), speech interference can be expected
when intruding noise levels exceed 60 to  65 dB.    Hence,  if  an
event produces an !•,„ above 65 dB at a location of interest
(e.g.,  residence,  school  room),  some  difficulty  maintaining
uninterrupted conversation can be expected.

In general, for  single noise events, a difference of  1 dB between
mflyinrnm levels produced by two  sequential single events may not be
noticeable to some people; a difference of 3 dB generally will be
detectable; a difference of 5 to 7  dB will be easily heard; and an
increase of  10 dB  is often judged to  be a doubling of loudness,
just as a decrease of 10 DB is perceived as a halving  of loudness.

Sound Exposure Level (SEL)

The maximum A-weighted  sound level, or L^ can be easily understood
in  terms of  everyday  experiences with  noise.    Slightly  more
complicated,  but in some ways more useful, is the sound exposure
level, abbreviated SEL.  The !•,„ describes only the loudest level
of an  event;  it does  not  describe how long the  event  lasted.
Subjective tests  indicate  that  human response  to  noise is  a
function not  only of the Tnayirnmn level, but also of the duration of


                             0-2.

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 the event and its  variation with respect to time.   The SEL is a
 measure of the physical energy of the noise event which takes into
 account both  intensity and  duration.   The SEL  is based  on the
 integral of the A-weighted sound level during the period it is
 above a  specified threshold  (that  is at least  10 dB  below the
 maximum value measured during the noise event) with reference to a
 standardized duration of 1 second.
 In general,  SEL is  higher than L.^, because it condenses the total
 sound energy of an  event into a one second interval, as though the
 whole event  occurred in  one  second.    Figure 1 illustrates  the
 relationship between SEL  and !•„,.  The  usefulness  of  SEL lies in
 the ease of  translation into other metrics for use  in prediction.
 For example,  the  computer programs that compute  noise  exposure
 around airports  base their  calculations  on  SEL  data for  each
 aircraft type (EPA 1977).

 2.3.2 Cumulative Noise Metrics

 Long-term cumulative noise metrics are usually derived from single
 event metrics or computed from continuous noise measurement data.
 Cumulative metrics correlate well with aggregate community response
 to the sound  environment.   Although cumulative metrics were  not
 designed as  single event measures,  they use  single event  data
 averaged over a specified time period.   Thus cumulative measures,
 like single  event measures,  can  relate to annoyance and to speech
 and sleep disturbance, although the relationship between cumulative
 measures  and sleep disturbance is not clearly established.   Common
 metrics used to characterize cumulative sound environments include
 the Equivalent Sound Level and th& Day-Night Average Sound Level.

 Equivalent Sound Level (1^,)

 Sound levels vary as time passes.  The variations can occur over
 very short periods  or,  variations  can be  longer term.   Several
 methods  have been used  to quantify time varying noises,  but  the
 most common  is the  Equivalent Sound Level, abbreviated L-_.  This
 sound level  accounts for  all sounds that occur in a given time
 period.   Briefly, it is the  level of a constant A-weighted sound
 that has exactly the same  amount  of total sound energy as  did  the
 actual time  fluctuating sound.   L., is  "equivalent" to an actual
 tune varying sound  level in  the  sense  that it  has the same total
 energy for the same length of time,  only  the fluctuations in level
 have  been  summed up and  "averaged" to yield a constant,   steady-
 state  level.   Thus,  the A-weighted sound  level  can be  used to
measure instantaneous sound levels as they occur, or  the A-weighted
 level  can be cumulative over a  longer  time  period to yield an
equivalent level.                              •         J

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                                                 NEPA: Airpon/Air Facility Noise
                       Figure 1: Relationship between SEL and
      110
01

LU
_i
Q
Z
      100
90
       80
           Stradad Araaa
           Repretent
           Equivalent
           Sound
           Energy
      70
                                                    SEL "108.0 dB
                                                   L--X - 102.5 dB


          I  i  i  i i i  n f i
                                   I  I  !«l I  I  !  I I 1  I  I  I
          TIME(t«G)
                        Sampling
                        IntanraJ
                        (6.8 S*c)

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The  following examples  are provided  to illustrate  how the  L.,
cumulative noise  metric works.   If a single event  lasting one
second at  90 dB occurs  every five or six minutes in a 24-hour
period, then the resultant  cumulative  noise  level  would be L^, 65
dB.  If the sound level of the one-second single events were only
80 dB, the events would have to occur every 34 seconds over the 24-
hour period to attain  a L^ 65 dB cumulative  noise level.  If the
sound level of the one-second single events were as high as 100 dB
occurring every five to six minutes, then the resultant cumulative
noise level would be L*, 75  dB.

Day-Night Average Sound Level (DHL or L^)

The Day-Night Average Sound Level (DHL)  is the Energy-Average Sound
Level (L^) measured over a period of 24 hours, with a 10  dB penalty
applied to nighttime  (10:00pm to .7:00am) sound levels to account
for increased annoyance by sound during the night hours.

The  DNL  was  selected  by  the EPA as  the uniform descriptor  of
cumulative sound  exposure  to  correlate with health  and welfare
effects.  Subsequently, all Federal agencies adopted yearly average
DNL  as  the basis  for  describing community noise  exposure.   DNL
takes into account the sound levels of all individual events that
occur during a 24 hour  period, and the number  of times those events
occur.   The averaging of sound over  a 24 hour period does not
ignore the louder single events, and it actually tends to emphasize
both  the  sound level  and  number of those events.  Although the
logarithmic  nature of the dB  unit causes  sound  levels  of the
loudest events to  control the 24 hour average,  DNL is still much
lower in  value than the maximum  sound level (L^u) of  individual
events.   DNL is considered a superior metric in  accounting for
variations  in the  noise environment  including  such  factors  as
numbers of events,  loudness of individual events, and percentage of
night events.

Annoyance

Annoyance is a summary measure of the general adverse reaction of
people  to noise  that generates  speech  interference  (including
inability  to use the  telephone, radio,  television or  recordings
satisfactorily) or sleep disturbance, or simply interferes with the
desire for a tranquil  environment.   Community response is a term
used  to  describe  the  annoyance of groups  of people  exposed to
environmental  noise   sources  in  residential  settings.    Case
histories  and social  surveys  indicate that the  response  of a
community to aircraft  noise is  affected not  only by how loud the
noise is, but also by how often noise events occur  (i.e., the total
noise exposure in a specified time period).  Currently, the best

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 available measure of this response is the percentage  of the  area
 population characterized  as  "highly annoyed"  (%HA) by long-term
 exposure to noise of a specified level (expressed in terWof
      tZ d?veJ;0pe1 " •*"»!*» *<« describing the relaonship
 between the level of exposure  (in DNL)  and %HA,  and the gra

 S^8IS^Li0LtS^sne£fl!onshlp is o£ten "S
 The relationship  between DHL  and %HA is  an invaluable  aid in
 assessing comminity  response since it  relates the  response to
 increases in both sound intensity and frequency of occurrence.  EPA
 proposed  %HA  as  the appropriate  impact criterion  to Se  for
 evaluating the  effects  of  noise  on communities   fEPA  1982?
 Although the predicted annoyance, in terms of  absolute levels, may
 vary among different communities, the  Schultz curve can reliably
 indicate changes in level of annoyance  for defined ranges of sound
 exposure for any given community."                          °«-»u««

 Interference with  Speech  and  Communication

 I???6^-1?1^8^6 noise exceeds approximately 60 dB indoors, there
 will be interference with speech communication.  This interference
 may result from masking of  the speaker's  words  or by causing SI
 speaker  to pause.  Increasing the indoor level of intrusive noise
 to  80 dB reduces  intelligibility to near zero,  even ifVloud voicl
 is   used.    Based  on  the  average  levels  of  noise  reduction
 (attenuation) provided by typical residential con.trnSt±S(SsS
 TiSon^   >,°P?1 *? 25  ** With windows  closed) , some  degree of
 indoor  speech  interference would be expected whenever  exterior

            8  6XC     "  ^ ^  ***  (windows
Sleep Disturbance
The effects of noise on sleep have long been a concern of parties
interested  in assessing  residential noise  environments.    Many
laboratory  studies were  conducted  during  the  1970 's  on  sleep
disturbance and awakening caused by noise.                   sj-eep
^foJ^^httime "penalty"  added to noise levels for the period
10: 00pm to 7: 00am in computing DNL is intended to account for the
intrusiveness of noise at night, partly due to the lower nighttime
ambient,  and  therefore   tends  to reflect to  some  extent  the
potential for wakeups. However, in some circumstances, such as an
unusual number  of  nighttime noise events, supplemental  analysis
(using SEL  or L^) to indicate  sleep disturbance is  desirable.
Figure 3 presents sleep disturbance  (% awakenings)  relative to
exposure to single event noise levels.



                            0-fe

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  Fig. 2: Interference with Speech & Communication
     100 i		
     80
  T3
  0)
     60
O
  D) 40
  X
  P
     20
               SCHULTZ DATA
          %HA=100/(1 +exp(10.43-0.13Ldn))
            45   50    55   60   65    7p   80   85   90
               Day-Night Average (sound level in dB)

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disturba»ce
                                        to exposure to single event
                       SLEEP DISTURBANCE
             AWAKENINGS - .000007079 x SEL ' 3.496
                OBSERVED
                PREDICTED
      50    60   70    80
      INDOOR SEL IN DECIBELS
                                                  100   110
Source:  Finegold et  al.  1992  IN:  FICON 1992.
                              0-S

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2.4.3 Honauditory Health Effects of Noise

Alleged nonauditoxy health consequences of noise exposure that have
been  studied include  birth  defects,  low  birth weight,  mental
problems,  cancer,   stroke,  hypertension,  sudden cardiac  death,
myocardial  infarction,  and  cardiac  arrhythmias.    Of  these,
hypertension  is  the most biologically plausible  effect of noise
exposure.  Noise appears to elicit many of the same biochemical and
physiological .reactions,  including temporary  elevation of blood
pressure,  as  do many other everyday stressors.   These temporary
increases  in blood pressure  are believed  to  lead to  a gradual
resetting  of the  body's blood  pressure control system.   Some
researchers  hypothesize that over  a  period of  years,  permanent
hypertension may develop  (Peterson et al., 1984). •

Most studies which have controlled for multiple factors have shown
no,  or  a very weak,  association between noise  exposure  and
nonauditoxy  health  effects.    The  current state  of  technical
knowledge  cannot  support inference of  a  causal or  consistent
relationship,  or  a  quantitative  dose-response  model,  between
residential  noise  exposure  and health  consequences.    Thus,  no
technical  means  are available for  predicting  nonauditory health
effects of noise exposure.  This  conclusion  cannot be construed as
evidence of no effect of residential noise exposure on nonauditory
health.   Current findings, taken in  sum,  indicate  that further
rigorous studies are needed.

2.5.1 Noise Exposure and Noise Impact

Before discussing noise impact  criteria, the distinction between
noise exposure and noise impact should be clarified.  DHL and other
metrics are used to describe noise exposure  levels; and similarly,
DHL  contours graphically  illustrate  cumulative  noise  exposure.
Noise impact, on the other hand, can only be assessed by relating
noise  exposure   levels  to  noise-sensitive   receptors  (i.e.,
residences, churches, schools, campgrounds, amphitheaters, etc.).
In  other words, noise impact  describes the  effect that noise
exposure levels  have upon  noise-sensitive  receptors at  a given
location.
                             0-*)

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 2.5.2  Threshold Criteria for  Change in Noise Exposure  (Relative
 Impact)

 DNL noise exposure  contours  are used to  show the cumulative noise
 exposure produced by a noise source.  Comparing noise contours  for
 two different analysis cases such as noise contours resulting from
 the  proposed action  and the  No-Build  cases,  it  is possible to
 identify  those  areas that  would   experience  a  change  in noise
 exposure.  When the change in  noise exposure is considered in
 relation to noise-sensitive receptors located within the contours,
 it may be referred  to as relative impact.

 The threshold criterion for relative impact is a 1.5 dB change over
 any noise-sensitive area located within the DNL 65 dB contour.   The
 threshold criteria of a 1.5 dB increase was derived from predicted
 annoyance using the  Schultz curve (discussed previously).    The
 Schultz curve can reliably indicate changes  in level of annoyance
 for defined ranges of sound exposure for any  given  community.   The
 Schultz curve shows that an increase of  5 dB  at DNL 55 dB, 3 dB at
 DNL 60 dB, and  1.5  dB at DNL 65 dB all  result in a three percent
 xncrease in %BA, since the gradient of the Schultz  curve decreases
 with decreasing DNL values  (refer  to Figure 2).   Therefore,  as
 threshold criteria  for change  in noise exposure,  a 3 dB change at
 DNL 60 dB and a 1.5 dB change  at DNL  65 dB are consistent.

 EPA supports using  %BA as  an appropriate impact  criterion to  use
 for evaluating  the effects of  noise on communities  (EPA 1982).

 Assessing  relative impact  can be  useful in  the  comparison  of
 project  alternatives.   If  the  merits   of  two alternatives   are
 relatively similar, the tie-breaker between alternatives should be
 based upon a comparison of %HA and  the number of persons impacted.
2.5.3 Land Use f mgpa-fcihi i j-Ky Exposure Criteria
Impacts occur when noise produced by a project exceeds a specified
threshold  level at  the location  of noise-sensitive  land uses.
Thresholds of noise exposure levels are  established as a guide for
determining compatibility with various land uses.  In most cases,
land use compatibility recommendations regarding noise are in the
form of guidelines provided by Federal agencies to State and local
communities.   In general, land use  compatibility  guidelines are
expressed  in  terms  of  DNL  and  include  (1)  identification  of
compatible and incompatible land uses on the basis of DNL in 5 dB
increments beginning at or below 65 dB, and (2) recommendations for
building  design and  construction methods  necessary to  achieve
specified  levels  of noise  attenuation  (reduction)  based  on the
outdoor DNL.
                             0 - 10

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For local agency decisions,  Federal  guidelines do not constitute
definite thresholds of unacceptable exposure, since local agencies
determine   the  application  of   the  guidelines   taking  into
consideration  economic,  technical,  and political  ramifications
specific to the communities involved.

The FICUN Guidelines  (1980)  provide a summary  table of Land Use
Applications and Compatibilities  for this purpose.   In general,
these guidelines have  been broadly accepted; however, there is a
need for selective updating  to  include new types of land use and
the need for improved public understanding of the guidelines.
                            O-H

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o  2:
 I   §

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                           REFERENCES


Federal Interagency Committee on Noise (FICON). 1992.  Federal
     Agency Review of Selected Airport Noise Analysis Issues.
     August 21, 1992.  U.S. Air Force, EPA, FAA.

Federal Interagency Committee on Urban Noise (FICUN).  1980.
     Guidelines for Considering Noise in Land Use Planning and
     Control.  (U.S. Government Office Report # 1981-337-
     066/8071) Washington, D.C.:  FICUN.

Peterson, E.A., J.S. Augenstein, and C.L. Hazelton.  1984.  Some
     Cardiovascular Effects of Noise.  Journal of Auditory
     Research.  24: 35-62.

U.S. Environmental Protection Agency (EPA). 1977.  Calculation of
     Day/Night LDN Resulting from Civil Aircraft Operations.
     EPA 550/9-77-450.

U.S. Environmental Protection Agency (EPA).  1978.  Noise:  A
     Health Problem.  August 1978.

U.S. Environmental Protection Agency (EPA).  1982.  Guidelines
     for Noise Impact Analysis.  EPA-550/9-82-105.  Springfield
     VA:  National Technical Information Service (PB82-219205).
     [As modified by EPA internal memorandum of 1992.]
                             0-13

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o

  1
 	
•-T

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            APPENDIX P



GOPHER TORTOISE RELOCATION REPORT

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                  APPENDIX P

      GOPHER TORTOISE RELOCATION REPORT

         Prepared by CZR Incorporated
               December 8, 1992
Note:  Photos do not reproduce well and are not
included.

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   CEDAR BAY COGENERATION PLANT

GOPHER TORTOISE RELOCATION REPORT
             December 8, 1992
               Prepared for:
           U.S. Generating Company
            7475 Wisconsin Avenue
            Betheseda, MD 20814
                Prepared by:
              CZR Incorporated
           4494 Southside Boulevard
            Jacksonville, FL  32216

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                    TABLE OF CONTENTS
                                                           PAGE






 1.0   INTRODUCTION	




                    ? on TTVTT/'-VXT
3.0   RECIPIENT SITE DESCRIPTION	        g



4.0   MANAGEMENT PLAN	            9




5.0   CONCLUSION	            9
6.0  LITERATURE CITED






Attachment A




Attachment B




Attachment C




Attachment D




Attachment E

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                           LIST OF FIGURES
 FIGURE




Figure 1




Figure 2




Figure 3




Figure 4
            DESCRIPTION
PAGE
Location Map of Donor and Preserve Sites	   2



Gopher Tortoise Burrow Survey Procedure	   3



Gopher Tortoise Scute Notching Procedure	   5



USDA Soils Map of Donor and Preserve Area	   7
                                    u
                        P-5

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                         LIST OF ATTACHMENTS
Attachment A


Attachment B

Attachment C

Attachment D


Attachment E
Aerial  Photographs  Depicting   Gopher
Tortoise Burrow Locations on Donor Site

Photographs of Gopher Tortoise Relocation

Gopher Tortoise Data Sheets

Photographs of Gopher Tortoise Habitat on
Donor Site

Photographs of Gopher Tortoise Habitat on
Preserve Site
                                    in
                        P-b

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1.0    INTRODUCTION

       In order to allow transportation of large equipment needed for construction of the Cedar
Bay Cogeneration Plant, U.S. Generating Company is constructing a railroad spur. The railroad
spur was designed to minimize environmental impacts.  However, impacts to a limited amount
of gopher tortoise (Gopherus pofyphemus) habitat were unavoidable.

       The railroad spur corridor (donor site) was surveyed for the presence of gopher tortoise
burrows and evidence of other species of special concern. Gopher tortoise burrows were found
on-site, and the possibility existed that the Florida mouse (Peromyscus floridanus), Florida
gopher frog (Rana aereolata  aesopus), and the Eastern indigo snake (Drymarchon  corals
couperf) may also  occur.  Protection of these species was  proposed  through live-capture and
relocation of these animals to an on-site preserve (Figure 1).

       CZR Incorporated utilized  Generic Gopher Tortoise Permit No.  WR92093 to relocate
nine gopher tortoises which were within the railroad  spur  boundaries.  These tortoises were
relocated in November 1992 to a preserve on-site where no future development is planned.

       Included in this report are descriptions of the donor and recipient sites, burrow survey
results,  burrow location maps, methodology for capture and transfer of protected animals,
management plan, and  monitoring and reporting plans.

Gopher Tortoise Burrow Survey

       Thorough surveys of the suitable gopher tortoise habitat within the railroad corridor were
conducted on November 4,  1992 in order to locate all active and inactive burrows which would
be impacted by the railroad construction.  Parallel transects were established 15 meters apart
starting at the  edge of  each area of suitable habitat. Within the  15 meter transect, biologists
walked transects 3  to 5 meters apart in a simulated  "S" pattern (Figure 2).  Burrows were
marked with orange surveyor tape if active and with  white if inactive.  The locations  of the
burrows and their status were mapped on an aerial photograph (Attachment A).
                                                 p-7

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                 >-  • n  •
                 .  i  u  p.......

                               (• •' tT M* •>
                               • •••••  *^ i
                              Polly Town *•,£
uul/^^l
                        LOCATION MAP
                                          _; _,^__ .f  ^
                                          --.::: a qA^Eti«^ao%
                                            ^ r>7-^>Cx. /  ->g ^L-
CP 1281
           CEDAR BAY
     COGENERATION PLANT

     	FIGURE 1   DECEMBER 1992
P-S
                                           INCORPORATED
                                     4494 Southside Blvd.
                                     Suite 200
                                     Jacksonville, Florida 32216

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   I   <—  15m  —> I   <—  15m  -->• I   <—  15m  —> I
Edge of Property
Person B
                                                   Person A

•
E
<
tape •>


. )
(
-
k. V ,
U
* J
r
^ j

\
\
f
\ .\
v. ^

f
i ,

.'
I
I )

, I

]
*

i
,-

K
v ^- Edge of Property
STANDARD GOPHER TORTOISE SURVEY PROCEDURE
CEDAR BAY COGENERATION PLANT
GOPHER TORTOISE RELOCATION PROJECT
CP1281 FIGURE 2 DECEMBER 1992
CZR INCORPORATED
4494 Southside Blvd.
Suite 200
Jacksonville. Florida 32216

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       The November 1992 survey yielded 10 active and 11 inactive burrows (Attachment A).
To determine the number of tortoises per burrow, Auffenberg and Franz (1982) suggest using
a ratio of 0.614 tortoises per number of active and  inactive burrows.  However, results of
previous excavations have found this conversion factor to be too high (CZR  1991, CZR 1989,
and Breininger, et.al.).  An average of the valid conversion factors from previous results was
taken, and a realistic conversion factor of 0.50 was developed.  Using this conversion factor
with the above survey results yielded the following prediction:

               21 (active burrows + inactive burrows) x 0.50 g.t./burrow =
                             10.5  g.t. to occur on donor site

       Research has found that under optimal  conditions, habitats can support viable  gopher
tortoise populations at a density of 2.2 tortoises  per acre (Cox, Inkley and Kautz, 1987).  Thus,
a minimum of 4.7 acres (0.45 acre/g.t. x 10.5 g.t.) of optimal habitat is required to support the
predicted tortoise population.  U.S.  Generating Company  selected 6.0 acres of habitat on the
site as a preserve (Figure 1).

       Methodology and Disposition

       Gopher  tortoises were excavated from  active and  inactive burrows  by  backhoe and
shovel, to within four feet of the burrow's end.   Excavation of the last four feet was completed
by shovel and hand (Attachment B).  A bucket trap was set at one burrow which could not be
excavated.

       Captured gopher tortoises were transported to the preserve/recipient  site under  shaded
and sanitary conditions. Marking of the tortoises followed the FGFWFC (1988) "Guidelines for
Gopher Tortoise Relocation" (Figure 3, Attachment C).
                                                F-io

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  Gopher Tortoise Marking
      Each tortoise will be permanently marked
      by drilling hole(s) in one  or a combination
      of the scutes.  Each  scute is assigned
      a numerical value as per the  scheme
      illustrated below. The scheme is additive  -
      tortoise  number 12 would require  the
      drilling of the number 10  scute and  the
      number 2 scute.
         GOPHER TORTOISE SCUTE NOTCHING PROCEDURE
CEDAR BAY COGENERATION PLANT
GOPHER TORTOISE RELOCATION PROJECT
CP 1281
FIGURE 3   DECEMBER 1992
                        CZR INCORPORATED
                        4494 Southside Blvd.
                        Suite 200
                        Jacksonville. Florida 32216

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2.0    DONOR SITE DESCRIPTION

       The railroad corridor is located south of Baisden (Kraft) Road and west of Eastport Road
in Duval County, Florida (Figure 1). The soil which occurs within this area is Alpin fine sand,
0 to 8 percent slopes, and Pottsburg fine sand (Figure 5).  Alpin fine sand is nearly level to
sloping, and is excessively drained soil on broad upland ridges.  The water table,  under normal
conditions, is at a depth of more than 72. This soil has a very rapid permeability rate and low
fertility.  Pottsburg fine sand is a nearly level, somewhat poorly drained soil. The water table
is at  a depth  of 6" to 12" for two-four months  and 12" to 40"  for six to  nine  months.
(USD A 1978).

       Based upon burrow survey results, gopher tortoises were located  in two areas along the
railroad corridor. Within these areas,  two basic habitats occur: laurel oak (Quercus laurifolia)
and scrub oak (Quercus spp.); and open field with no canopy cover.  The groundcover within
the  laurel oak habitat consists primarily of saw palmetto (Serenoa repens), wiregrass (Aristida
stricta), blackberry (Rubus sp.), greenbrier (Smilax laurifolia), and pawpaw (Asimina reticulata).
The open field is dominated by wiregrass, broom sedge (Andropogon spp.), blackberry, lupine
(Lupinus sp.),  milkweed (Ascelpias humistrara), dog fennel (Eupatorium sp.), and prickly pear
cactus (Opuntia sp.) (Attachment D).

       Wildlife known to occur on the donor site include the gopher tortoise, raccoon (Procyon
lotof), armadillo (Dasypus  novemcinctus),  whitetail deer (Odocoileus  hemionus),  six-lined
racerunner (Cnemidophorus sexlinearus), ground skink  (Leiolopisma  larerale),  green anole
(Anolis carolinensis), bluejay (Cyanocina crisiara), mockingbird (Miinus polyglorrus), Carolina
wren (Troglodytes carolinensis}, and white-eyed vireo (Vireo griseus).
                                                  F-lZ.

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                                   SOILS MAP
CP 1281
       CEDAR BAY
COGENERATION PLANT
         FIGURE 4   DECEMBER 1992
                                                 CZ/R  INCORPORATED
                                                 4494 Southside Blvd.
                                                 Suite 200
                                                 Jacksonville, Florida 32216

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 3.0   RECIPIENT SITE DESCRIPTION

       A parcel west of Eastport Road was selected as the recipient site and preserve for the
 gopher tortoises impacted by the proposed railroad  (Figure 1).  The preserve is composed of
 turkey and scrub oak habitats.  Seminole Kraft maintains a fence along this property boundary
 which would inhibit gopher tortoises from wandering off of the relocation area.

       The 6.0 acre preserve is optimal habitat with an average  of 75% canopy cover.
 Groundcover is approximately 85% and will provide plenty of food for the relocated tortoises
 (Attachment E). Habitat suitability and the presence of abandoned burrows, suggests this area
 to be a desirable relocation site.

       Soils on the preserve are mapped as Alpin  fine sand  with 0  to 8 percent slopes  and
 Pottsburg fine sand (Figure 4).  These sand classifications are identical to those found on the
 donor site and will provide similar functions.

       The preserve includes two basic habitat types. The predominant habitat has  a canopy
 (75% cover) of turkey oak and long leaf pine. The groundcover averages 85% and consists
 primarily of wiregrass, pawpaw, highbush blueberry (Vaccinium corymbosum), stinging nettle
 (Cnidoscolus stimulosus), butterfly pea, and stargrasses.  This community has scattered open
 areas vegetated with wiregrass, tar flower (Befaria racemosa), broom sedge, lupine, and bracken
 fern (Pteridiwn aquilinium).

       Armadillo and raccoon tracks were found on-site.  The birds  observed include tufted
titmi>i (Parus bicolor), mockingbirds, fish crows, grackles, black vultures (Coragyps atratus),
and cardinals.  Numerous six-lined racerunners were seen scurrying among the leaf litter.

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4.0    MANAGEMENT PLAN

       The general requirements for suitable gopher tortoise habitat are: 1) well drained, sandy
soils which allow easy burrowing; 2)  diverse and abundant groundcover; and 3) open  canopy
which allows sunlight to reach the ground (Diemer, 1986; Auffenberg and Franz,  1982).  All
of the above conditions are present on the recipient site. However, we suggest controlled bums
every five years to increase the diversity and abundance of vegetation.  Because the site is also
directly adjacent to Eastport Road, it  will be necessary to maintain the fencing to decrease the
chance of roadway mortalities.
 5.0   CONCLUSION

       The gopher tortoise relocation project on the Cedar Bay Cogeneration railroad spur
 successfully and safely cleared the area of tortoises.  A total of 21 gopher tortoises burrows were
 excavated.  Nineteen burrows were excavated by backhoe, shovel, and hands.  One burrow was
 partially excavated with a backhoe and then observed for thirty-days.  This burrow was inactive
 during thirty-days when other tortoises were active and,  therefore, was determined to be
 abandoned.  One burrow disturbed fitted with a bucket trap because it was too close to the
 railroad tracks to excavate. A five-gallon plastic bucket was sunk at the burrow's mouth and
 monitored three times a day for four days.

        Nine gopher tortoises were relocated from the railroad spur boundaries.  These nine
 tortoises included two females, four males,  and  three juveniles.  The largest tortoise with the
 longest burrow was a 5 kg (10.5 Ibs) female. This tortoise was 29.6 cm (11.65") long and 22.2
 cm (8.74") wide with a burrow 7.13m (23.5') long and 2.59m (8.5') deep. The tortoise burrows
 excavated varied from less than 1m to 7.13m long and less than  1m to 2.59m deep.

        Juvenile  tortoises are too young to  determine  their gender.  One juvenile was found
  walking across a spoil pile, and not in a burrow.  Because it was impossible to determine where
  the tortoise came from, we relocated it to the preserve. All of the juveniles were released into
  abandoned burrows and showed no hesitation in accepting the new burrow.


                                            9       P-15

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       The only difficulty encountered during relocation involved an adult female with a minor
carapace crack.  This female was found buried in the spoil area at the edge of the excavated
burrow.   She had a  three inch crack along the back of the carapace, but otherwise  was
unharmed. To guarantee her safety, this tortoise was transported to  the Jacksonville Zoo for
examination by Dr. Douglas Page, DVM. The crack was cleaned, treated with antibiotics, and
then filled with epoxy. Because the weather was below 50°F at night, the tortoise was held at
the zoo for fifteen days. During the first period of 70-75 °F weather,  the tortoise was released
onto the preserve into an abandoned burrow.

       The remaining five  adult tortoises were also relocated  on the preserve. Some of the
tortoises  accepted abandoned burrows, others utilized starter burrows dug by CZR biologists.
Because a cool weather front moved through the area  two days after relocation, the tortoises
were inactive and remained within the preserve.

       As of November 23, no gopher tortoises had moved back into the railroad spur corridor.
Although the cooler weather will most likely keep the tortoises inactive, we would  recommend
that a  burrow survey be completed within a week prior to  railroad  construction.  There are
additional tortoise burrows  adjacent to the proposed corridor. If the spur alignment is altered,
it will  be necessary to survey the new areas for burrows.
                                           ,o

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6.0   LITERATURE CITED

Auffenberg, W. and R. Franz. 1982. The Status and Distribution of the Gopher Tortoise
      (Gopherus polyphemus).  Pg. 95-126 in R.B.  Bury (ed.) North American Tortoises:
      Conservation and Ecology.  USDI, Fish and Wildlife Service.  Res. Rep. 12.  126 pp.

Breininger, D., A. Schmalzer, D. Rydene, and R. Hinkle. Burrow and Habitat Study of the
      Gopher Tortoise in Scrub and Flatwood Habitat Types.  Final Project   Report, Project
      No. GFC-94-016, Nongame Wildlife Program,  Florida Game and Fresh Water Fish
      Commission. Tallahassee, FL.

Cox, J., D. Inkley, and R. Kautz.  December 1987. "Ecology and Habitat  Protection Needs of
      Gopher Tortoise (Gopherus polyphemus) Populations Found on Lands Slated for Large-
      scale Development in Florida."  Florida Game and Fresh Water Fish  Commission.
      Nongame Wildlife Program Technical Report No. 4.

CZR Incorporated.  July 1991.  University of North Florida Gopher Tortoise Relocation.

CZR Incorporated.  June 1989.  Palm Beach County School Board Site GGG Gopher Tortoise
      Relocation Plan.

Diemer, J.E.  1986. The Ecology and Management of the Gopher Tortoise in the Southeastern
      United States.   Herpetologica 43:125-133.

U.S. Department of Agriculture. 1978. Duval County Soil Survey, Florida. Washington, D.C.
                                         11

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 ATTACHMENT A
P-IS

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          APPENDIX Q

RESOLUTION OF UNRESOLVED ISSUES
     FROM THE DRAFT EIS/SAR

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       RESOLUTION OF  "UNRESOLVED ISSUES" FROM DRAFT EIS/SAR

      In the Draft EIS/SAR, six issues were listed as  "unresolved
 issues."  Subsequent to Draft EIS/SAR publication,  these issues
 were resolved through project design changes and/or new
 information provided by the applicant.  Issues  are addressed as
 follows:

      "Air Quality - It is unclear  at this  time  whether SNCR
 should represent BACT for the AES-CB boilers.   Therefore,  it is
 important that all available information concerning the proposed
 level of BACT and the SNCR alternative be  submitted by AES-CB
 prior to the issuance of the Final EIS.  This information  should
 include, among other things, a comparative analysis between the
 AES-CB boilers and other CFB's which have  been  required to
 install SNCR.  This analysis should document any  differences in
 energy,  environmental,  or economic concerns, between  the
 facilities so that a final BACT recommendation  can  be made."

   •   The CBCP will employ SNCR for NOx control.

      "Erosion and Sediment Control Plan -  Revisions to the
 Erosion and Sediment Control Plan  submitted by AES-CB will be
 necessary before it is  consistent  with requirements of Part  III.D
 of the draft NPDES  permit and can  be considered an  acceptable
 Plan.   Specific concerns include:   absence of inspection,
 monitoring and reporting requirements;  potential  runoff from the
 lime mud storage area;  potential runoff  from unusable material
 which is to be stockpiled on the north end on the SK  site; and
 apparently inadequate size of the  Yard Area Runoff  Pond."

   •   AES-CB submitted an acceptable Plan before construction.

      "SK Conversion to  Recycled Paperboard - SK is  planning  to
 convert  their facilities to accommodate  recycled  paperboard,
 replacing wood as a raw material in their  operations.   SK
 conversion to recycled  paperboard  will significantly  reduce  the
 SK waste flow and will  change the  characteristics of  the combined
 SK/CBCP  effluent from that which has presently been provided in
 the  SCA.   Re-evaluation of the waste flow  is needed in  the Final
 EIS.   In addition,  it is unclear whether or not wood wastes will
 be burned at  CBCP after conversion to recycled paperboard.   This
 could  affect  air quality evaluations.  Clarification  is needed in
 the  Final  EIS."

   •  SK  waste flow  characteristics  have been re-evaluated in this
     Final EIS.  Wood waste will not be burned in the CBCP
     boilers,  but fiber rejects from the SK recycle operation
     will  be  burned if  feasible.  Air quality impacts have been
     evaluated in this  Final  EIS.

     "Toxicitv of CBCP Waste  Stream - Some agreement will have to
be established between AES-CB  and SK as to how resolution of
future toxicity problems will be effected,  should they occur, if

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 CBCP wastes discharged into the SK system prove to be more toxic
 2£?JEe8en*ly a?ticiPated and "suit in the SK effluent being
 acutely toxic.  Present evaluation indicates that additional
 treatment and/or dilution in the SK treatment system may render
 the combined waste not acutely toxic.  However, the SK   renQer
 manufacturing process is being modified and dilution flow will
 decrease in the future.  SK is (and will remain) subject to
 svstem Y ?nniH^?g °VhV°*al effluent Citing its treatment
 system.  In addition, facilities at SK (some of which may have
 been operation for 10 to 20 years of more)  may be approaching
 useful life expectancy.  EPA has no assurance that SK will be in
 operation over the useful lifetime of the CBCP.  Assurances on
 these points prior to the Final EIS issuance are desirable."

   *  J8 *h?^CBC? has been redesigned to be a "zero-discharge"
      facility, it will add no discharges to the SK system.  SK
      has updated the mill to a recycle facility.  Water system
      characteristics are evaluated in this  Final EIS.

    .  "Waste Effluent Treatment Systems - Details on treatment
 B££?n8v,pr?p08ed 5°r dewaterin
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