United States
Environmental Protection
Agency

m EPA

Region 4

345 Courtland St., N.E.
Atlanta, GA 30365

EPA 904/9-90-003a
May 1990

Environmental
Impact Statement

FDER State Analysis

Report

DRAFT

Cedar Bay Cogeneration Project
Jacksonville, Florida

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EPA

NPDES Application Number:
FL 0041173

Florida Power Plant Siting
Application Number:
PA 88-25

Draft

Environmental Impact Statement
for

Proposed Issuance of a New Source National
Pollutant Discharge Elimination System Permit

Florida State Analysis Report
for

Proposed Certification by the Governor and Cabinet

to

Applied Energy Services, Inc
Cedar Bay Cogeneration Project

Jointly Prepared by:

U.S. Environmental Protection Agency Region IV

and

Florida Department of Environmental Regulation

Applied Energy Services, Inc. propose to construct and operate a New Source
cogeneration facility on an existing industrial site within the North District
of Duval County, approximately eight miles north of Jacksonville, Florida.
The plant will produce 225 megawatts of electricity for sale to the Florida
Power and Light Company. In addition, steam will be sold to the adjacent
Seminole Kraft Corporation paper mill. This document assesses the proposed
project and alternatives with respect to impacts on the natural and man-made
environments. Potential mitigative measures are also evaluated.

The comment period will end on or about July 23, 1990.

Comments or inquiries should be directed to:

Heinz Mueller	Hamilton S. Oven, Administrator

EIS Project Officer	Power Plant Siting

U.S. EPA, Region IV	Florida DER

345 Courtland St., N.E.	2600 Blair Stone Road

Atlanta, Georgia 30365	Tallahassee, Florida 32301

(404) 347-3776	(904) 488-0130

Approved by:

R.	5 / 2l /30

Jreer C. Tidwell	Date

G'

Regional Administrator

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EXECUTIVE SUMMARY

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DATE DUE







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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.

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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. Major 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 were evaluated
considering the state of the art of emission control technology,

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environmental impacts,and economics. Major sulfur dioxide
(SO2) 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 "systSn""ciesrgn'ed"'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 (N0X) 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 N0X 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.

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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 capability 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.

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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 includes 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 SO2 and NOo. 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.

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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 N0X 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 Major 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
polyphemus) 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.

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 sedimejit control
plan and effective treatment of wastewater 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.

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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.

xi i i

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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 quality 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 N0X 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 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.

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

xi v

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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.

xv

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CHAPTER 1

INTRODUCTION

CHAPTER 2 ALTERNATIVES, INCLUDING THE

PROPOSED PROJECT

CHAPTER 3 AFFECTED ENVIRONMENT

CHAPTER 4

ENVIRONMENTAL CONSEQUENCES OF
THE ALTERNATIVES AND THE
PROPOSED PROJECT

CHAPTER 5

SUMMARY OF POTENTIAL ADVERSE
IMPACTS OF THE PROPOSED PROJECT
AND APPLICABLE MITIGATIVE MEASURES

CHAPTER 6 SUMMARY OF SAR/EIS FINDINGS
CHAPTER 7 LIST OF PREPARERS

CHAPTER 8

PUBLIC PARTICIPATION AND
COORDINATION EFFORTS

CHAPTER 9 BIBLIOGRAPHY

APPENDICES

TABLE OF CONTENTS

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TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY

TABLE OF CONTENTS		i

LIST OF APPENDICES		ix

LIST OF TABLES		x

LIST OF FIGURES		xii

LIST OF ACRONYMS AND ABBREVIATIONS		xiii

1.0 INTRODUCTION		1-1

1.1	US EPA AND FDER RESPONSIBILITY FOR THE SAR/EIS		1-1

1.1.1	USEPA Responsibility for the EIS		1-1

1.1.2	FDER's Responsibility for the SAR		1-2

1.1.3	Memorandum of Understanding for Preparation of a Joint
SAR/EIS Document		1-2

1.2	OTHER FEDERAL REQUIREMENTS		1-3

1.3	COORDINATION BETWEEN USEPA AND FDER		1-3

1.4	BACKGROUND OF THE PROJECT		1-4

1.4.1	Identification of the Applicants		1-4

1.4.1.1	AES/Cedar Bay Incorporated (AES-CB)		1-4

1.4.1.2	Seminole Kraft Corporation (SK)		1-4

1.4.2	History of the Project		1-5

1.4.3	Permit Applications		1-5

1.5	NEED FOR THE PROJECT		1-5

1.6	ISSUES TO BE ADDRESSED IN THE SAR/EIS		1-8

2.0	ALTERNATIVES, INCLUDING THE PROPOSED PROJECT		2-1

2.1	REGULATORY PREROGATIVES		2-1

2.1.1	Alternatives Available to USEPA		2-1

2.1.1.1	Issuance of the NPDES Permit		2-1

2.1.1.2	Denial of the NPDES Permit		2-2

2.1.2	Alternatives Available to FDER		2-2

2.1.2.1	PSD Permit		2-3

2.1.2.2	State Site and 401 Certification		2-3

2.1.3	Alternatives Available to Other Permitting Agencies....	2-3
2.2 THE APPLICANT'S PROPOSED PROJECT		2-4

2.2.1	The Project Site		2-4

2.2.2	Plant Orientation and Appearance		2-6

2.2.3	Power Generation System		2-6

2.2.4	Fuel Transportation and Handling		2-7

2.2.5	Air Emission Control System		2-7

2.2.5.1	TPS and Fugitive Dust Controls		2-7

2.2.5.2	SOx Controls		2-8

2.2.5.3	Control of other Boilder Emissions		2-8

2.2.5.4	Fugitive Dust		2-8

2.2.6	Cooling System		2-9

2.2.7	Wastewater Treatment Systems		2-9

2.2.8	Solid Waste Handling and Disposal		2-11

2.2.9	Transmission Facilities		2-11

2.2.10	Resource Requirements		2-11

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2.3	SITE ALTERNATIVES		2-13

2.4	PLANT SYSTEMS ALTERNATIVES		2-13

2.4.1	Cooling Systems		2-14

2.4.1.1	Cooling Facilities		2-14

2.4.1.1.1	Once-Through Cooling		2-14

2.4.1.1.2	Wet Natural Draft Cooling Towers		2-14

2.4.1.1.3	Mechanical Draft Cooling Towers		2-15

2.4.1.1.4	Dry and Wet-Dry Cooling Towers		2-15

2.4.1.2	Cooling Water Sources		2-16

2.4.1.2.1	Surface Water		2-16

2.4.1.2.2	Recycled Wastewater		2-16

2.4.1.3	Cooling Water Discharge Alternatives		2-17

2.4.1.3.1	Discharge to the Broward River		2-18

2.4.1.3.2	Recycle Cooling Water		2-18

2.4.2	Water System Alternatives		2-18

2.4.2.1	Potable Water Systems		2-19

2.4.2.2	Makeup Demineralizer System		2-19

2.4.2.3	Other Water Uses		2-19

2.4.3	Wastewater Treatment Systems Alternatives		2-20

2.4.3.1	Sanitary, Plant Process, and Chemical Wastewater
Collection		2-20

2.4.3.2	SK Industrial Wastewater System		2-21

2.4.3.3	Treatment of Recirculating Cooling Water		2-22

2.4.3.3.1	Bromochlorination		2-22

2.4.3.3.2	Ozonation		2-23

2.4.4	Air Pollution Control System		2-23

2.4.4.1	Particulate Control		2-24

2.4.4.2	Sulfur Dioxide Control		2-24

2.4.4.3	Alternative Controls for Other Emissions		2-24

2.4.5	Solid Waste Management Alternatives		2-26

2.4.5.1	Bed Ash		2-26

2.4.5.2	Fly Ash		2-27

2.4.5.3	Hazardous Waste		2-27

2.4.6	Materials Handling Systems Alternatives		2-28

2.4.6.1	Construction Materials and Equipment		2-28

2.4.6.2	Limestone Handling		2-28

2.4.6.3	Ash Handling		2-29

2.4.6.4	Coal Delivery and Handling		2-29

2.5	NO ACTION ALTERNATIVE		2-31

2.6	POWER GENERATION ALTERNATIVES		2-32

2.6.1 Fuel Types		2-32

2.6.1.1	Nuclear		2-32

2.6.1.2	Municipal Solid Wastes			2-33

2.6.1.3	Coal Gas		2-34

2.6.1.4	Solar		2-35

2.6.1.5	Wind			2-36

2.6.1.6	Hydroelectric		2-36

2.6.1.7	Ocean Tides		2-37

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2.6.2 Technology Types		2-37

2.6.2.1	Conventional Coal-Fired Steam Turbine		2-37

2.6.2.2	Combustion Turbine		2-38

2.6.2.3	Combined Cycle		2-39

2.6.2.4	Photovoltaic Cells		2-39

2.6.2.5	Passive Collection Panels		2-40

2 . 7 MANAGEMENT ALTERNATIVES		2-40

2.7.1	Purchase of Power		2-40

2.7.2	Joint Projects		2-41

2.7.3	Conservation		2-42

2.7.3.1	Demand-Side Conservation Practices		2-42

2.7.3.2	Supply-Side Conservation Practices		2-43

2.8 ALTERNATIVE MEANS OF SATISFYING THE NEED FOR THE PROJECT		2-43

2.8.1	Need for Analysis of Alternatives		2-43

2.8.2	Available Technologies for Oil and Gas Displacement....	2-45

2.8.3	Development of Alternatives		2-46

2.8.3.1	Criteria for Alternatives Development		2-46

2.8.3.2	Alternative 1		2-47

2.8.3.3	Alternative 2		2-50

2.8.3.4	Alternative 3		2-51

2.8.3.5	Alternative 4	'		2-53

2.8.3.6	Alternative 5		2-54

2.8.4	Economic Analysis of the Alternatives Including

the Proposed Project		2-55

3.0 AFFECTED ENVIRONMENT		3-1

3.1	AIR RESOURCES		3-1

3.1.1	Climatological/Dispersion Characteristics		3-1

3.1.2	Air Quality		3-2

3.1.3	Existing Air Pollution Sources		3-3

3.1.4	Regulatory Framework		3-3

3.1.4.1	Federal Regulatory Requirements		3-3

3.1.4.2	State Regulatory Requirements		3-9

3.2	SURFACE WATER RESOURCES		3-9

3.2.1	St. Johns River at Jacksonville		3-10

3.2.2	Broward River		3-15

3.2.3	Surface Water Uses		3-15

3.2.3.1	Water Withdrawal		3-16

3.2.3.2	Water Discharges		3-16

3.3	GROUNDWATER RESOURCES		3-18

3.3.1	Regional Groundwater Systems		3-18

3.3.2	Groundwater Use		3-19

3.3.3	Groundwater Quality		3-23

3.4	EARTH RESOURCES		3-26

3.4.1	Physiography and Topography		3-26

3.4.2	Soils and Geotechnical Conditions		3-26

3.4.3	Regional Geology		3-27

3.4.4	Site Geology		3-27

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3.5	AQUATIC AND TERRESTRIAL ECOLOGY		3-28

3.5.1	Aquatic Ecology		3-28

3.5.1.1	Flora		3-28

3.5.1.2	Fauna		3-29

3.5.2	Terrestrial Ecology		3-30

3.5.2.1	Site Area Vegetation		3-31

3.5.2.2	Site Wildlife		3-31

3.5.2.3	Biological Sensative Areas and Resources		3-31

3.6	CULTURAL RESOURCES		3-32

3.6.1 CBCP Site		3-32

3.7	EXISTING SOCIAL AND ECONOMIC CONDITIONS		3-33

3.7.1	Population Levels		3-34

3.7.2	Economic Conditions		3-37

3.7.2.1	Employment		3-37

3.7.2.2	Income		3-37

3.7.2.3	Housing		3-40

3.7.3	Community Services		3-41

3.7.3.1	Water Supply and Wastewater Treatment		3-41

3.7.3.2	Public Safety		3-43

3.7.3.3	Education		3-43

3.7.3.4	Health Care		3-44

3.8	LAND USES, RECREATIONAL RESOURCES, AND AESTHETIC

CONDITIONS		3-45

3.8.1 Cedar Bay Cogeneration Project Area		3-45

3.8.1.1	Existing Land Cover		3-46

3.8.1.2	Existing Land Uses		3-46

3.8.1.3	Projected Land Uses		3-50

3.8.1.4	Existing Zoning		3-50

3.8.1.5	Recreational Resources		3-51

3.8.1.6	Aesthetic Conditions		3-51

3.9	EXISTING TRANSPORTATION		3-52

3.10	SOUND QUALITY		3-54

3.11	ENERGY RESOURCES		3-58

3.11.1	Florida		3-58

3.11.1.1	Traditional Energy Sources		3-58

3.11.1.2	Other Energy Sources		3-60

3.11.2	Peninsular Florida		3-60

3.11.2.1	FP&L		3-60

3.11.2.2	JEA		3-61

3.12	HUMAN HEALTH		3-62

3.12.1	Mortality and Morbidity		3-62

3.12.2	Lung Cancer in the Jacksonville Area		3-62

4.0 ENVIRONMENTAL CONSEQUENCES OF THE ALTERNATIVES AND THE

PROPOSED PROJECT		4-1

4.1 CRITERIA FOR EVALUATION OF IMPACTS		4-1

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4.2	AIR QUALITY IMPACTS		4-4

4.2.1	Construction-Related Impacts		4-4

4.2.1.1	CBCP		4-4

4.2.1.2	Alternatives		4-6

4.2.2	Operation-Related Impacts		4-6

4.2.2.1	CBCP		4-6

4.2.2.1.1	Emissions Generated		4-6

4.2.2.1.2	Impacts on Soils and Vegetation		4-9

4.2.2.1.3	Impacts on Visibility		4-9

4.2.2.1.4	Nonattairunent Areas Impact		4-14

4.2.2.1.5	Growth-Related Air Quality Impacts		4-15

4.2.2.1.6	GEP Stack Height Determination		4-15

4.2.2.1.7	Best Available Control Technology (BACT)		4-16

4.2.2.1.8	Acid Rain		4-20

4.2.2.1.9	Coal Dust From Trailers		4-23

4.2.2.1.10	Trace Elements		4-24

4.2.2.1.11	Fugitive Dust		4-26

4.2.2.1.12	Global Climate Change		4-28

4.2.2.2	Alternatives		4-28

4.2.3	Comparison of Impacts		4-29

4.3	SURFACE WATER IMPACTS		4-29

4.3.1	Construction-Related Impacts		4-30

4.3.1.1	CBCP		4-30

4.3.1.2	Alternatives		4-32

4.3.2	Operation-Related Impacts		4-32

4.3.2.1	CBCP		4-32

4.3.2.1.1	Area Runoff		4-32

4.3.2.1.2	Cooling Tower Blowdown		4-34

4.3.2.1.3	Other Plant Effluent Streams		4-35

4.3.2.1.4	Steam Cycle Water Treatment		4-37

4.3.2.1.5	Sanitary Wastewater Treatment		4-39

4.3.2.1.6	Makeup Water Demineralization		4-39

4.3.2.1.7	Return Condensation Polishing		4-39

4.3.2.1.8	Metal Cleaning (Chemical and Nonchemical) Wastes	4-40

4.3.2.1.9	Miscellaneous Chemical Drains		4-41

4.3.2.1.10	Neutralization Basin		4-41

4.3.2.2	Alternatives		4-42

4.3.3 Comparison of Impacts		4-42

4.4	GROUNDWATER IMPACTS		4-42

4.4.1	Construction-Related Impacts		4-42

4.4.1.1	CBCP		4-42

4.4.1.1.1	Water Table Zone		4-42

4.4.1.1.2	Shallow Aquifer		4-43

4.4.1.1.3	Floridan Aquifer		4-43

4.4.1.2	Alternatives		4-43

4.4.2	Operation-Related Impacts		4-43

4.4.2.1	CBCP		4-43

4.4.2.2	Alternatives		4-45

4.4.3	Comparison of Impacts		4-46

4.5	GEOLOGICAL IMPACTS		4-46

4.5.1 Construction-Related Impacts		4-46

4.5.1.1	CBCP		4-46

4.5.1.2	Alternatives		4-47

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4.5.2	Operation-Related Impacts		4-47

4.5.2.1	CBCP		4-47

4.5.2.2	Alternatives		4-49

4.5.3	Comparison of Impacts		4-49

4.6	IMPACTS ON SOUND QUALITY		4-49

4.6.1	Construction-Related Impacts		4-49

4.6.1.1	CBCP		4-49

4.6.1.2	Alternatives		4-50

4.6.2	Operation-Related Impacts		4-51

4.6.2.1	CBCP		4-51

4.6.2.2	Alternatives		4-51

4.6.3	Comparison of Impacts		4-51

4.7	AQUATIC AND TERRESTRIAL ECOLOGY IMPACTS		4-52

4.7.1	Construction-Related Impacts		4-52

4.7.1.1	CBCP		4-52

4.7.1.1.1	Terrestrial Wildlife		4-52

4.7.1.1.2	Aquatic Life		4-53

4.7.1.2	Alternatives		4-54

4.7.2	Operation-Related Impacts		4-55

4.7.2.1	CBCP		4-55

4.7.2.1.1	Terrestrial Wildlife		4-55

4.7.2.1.2	Aquatic Life		4-55

4.7.2.2	Alternatives		4-55

4.7.3	Comparison of Impacts		4-56

4.8	IMPACTS ON CULTURAL RESOURCES		4-56

4.8.1	Construction-Related Impacts		4-56

4.8.1.1	CBCP		4-56

4.8.1.2	Alternatives		4-56

4.8.2	Operation-Related Impacts		4-57

4.8.2.1	CBCP		4-57

4.8.2.2	Alternatives		4-57

4.8.3	Comparison of Impacts		4-57

4.9	SOCIOECONOMIC IMPACTS		4-57

4.9.1	Population Impacts		4-57

4.9.1.1	CBCP		4-57

4.9.1.2	Alternatives		4-58

4.9.2	Economic Impacts		4-58

4.9.2.1	CBCP		4-58

4.9.2.2	Alternatives		4-58

4.9.3	Community Services Impacts		4-59

4.9.3.1	CBCP		4-59

4.9.3.2	Alternatives		4-59

4.9.4	Comparison of Impacts		4-59

4.10	IMPACTS ON LAND USE, RECREATION, AND AESTHETIC CONDITIONS...	4-60

4.10.1	CBCP		4-60

4.10.2	Alternatives		4-61

4.10.3	Comparison of Impacts		4-62

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4.11	IMPACTS ON TRANSPORTATION		4-62

4.11.1	Construction-Related Impacts		4-62

4.11.1.1	CBCP		4-62

4.11.1.2	Alternatives		4-63

4.11.2	Operation-Related Impacts		4-63

4.11.2.1	CBCP		4-63

4.11.2.2	Alternatives		4-63

4.11.3	Comparison of Impacts		4-64

4.12	ENERGY IMPACTS		4-64

4.12.1	CBCP		4-64

4.12.2	Alternatives		4-65

4.12.3	Comparison of Impacts		4-65

5.0 SUMMARY OF POTENTIAL ADVERSE IMPACTS OF THE PROPOSED PROJECT

AND APPLICABLE MITIGATIVE MEASURES		5-1

5.1	SUMMARY OF ADVERSE IMPACTS		5-1

5.1.1	Air Resources		5-1

5.1.2	Surface Water Resources		5-1

5.1.3	Groundwater Resources		5-2

5.1.4	Geological Resources		5-3

5.1.5	Aquatic and Terrestrial Ecology		5-3

5.1.6	Sound Quality		5-3

5.1.7	Cultural Resources		5-4

5.1.8	Socioeconomic Conditions		5-4

5.1.9	Land Use, Recreation, and Aesthetics		5-4

5.1.10	Transportation		5-4

5.1.11	Energy Resources		5-5

5.2	IDENTIFICATION AND EVALUATION OF AVAILABLE MITIGATIVE

MEASURES		5-5

5.2.1	Air Resources		5-5

5.2.2	Surface Water Resources		5-7

5.2.3	Groundwater Resources		5-7

5.2.4	Geological Resources		5-8

5.2.5	Aquatic and Terrestrial Ecology		5-8

5.2.6	Sound Quality		5-9

5.2.7	Cultural Resources		5-9

5.2.8	Socioeconomic Conditions		5-9

5.2.9	Land Use, Recreation, and Aesthetics		5-9

5.2.10	Transportation		5-9

5.2.11	Energy Resources		5-10

5.3	UNAVOIDABLE ADVERSE IMPACTS		5-10

5.3.1	Atmospheric Resources		5-10

5.3.2	Land Resources		5-11

5.3.3	Water		5-11

5.3.4	Sensitive Areas		5-11

5.4	RELATIONSHIP OF SHORT-TERM USES OF MAN'S ENVIRONMENT AND
MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY		5-12

5.5	IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES		5-12

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6.0 SUMMARY OF SAR/EIS FINDINGS		6-1

6.1	SUMMARY OF ECONOMIC ANALYSIS		6-1

6.2	SUMMARY OF ENVIRONMENTAL ANALYSIS		6-1

6.2.1	Construction-Related Impacts		6-2

6.2.2	Operation-Related Impacts		6-2

6.3	ALTERNATIVES TO THE PROPOSED PROJECT		6-6

6.4	RECOMMENDED COURSE OF ACTION		6-7

6.4.1	USEPA Environmentally Preferred Alternative and

Recommended Action		6-7

6.4.2	FDER Recommendations		6-8

6.4.3	Unresolved Issues		6-8

7.0 LIST OF PREPARERS		7-1

7.1	U.S. ENVIRONMENTAL PROTECTION AGENCY		7-1

7.2	FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION		7-1

7.3	GANNETT FLEMING, INC		7-2

8.0 PUBLIC PARTICIPATION AND COORDINATION EFFORTS		8-1

8.1	PUBLIC PARTICIPATION		8-1

8.2	AGENCIES, ORGANIZATIONS, AND INDIVIDUALS INCLUDED IN THE
SAR/EIS REVIEW PROCESS		8-2

9.0 BIBLIOGRAPHY		9-1

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APPENDIX - SAR/EIS (Bound Separately in Technical Appendix)

A	PSD PRELIMINARY DETERMINATION (FDER) (NOT INCLUDED)

B	PUBLIC NOTICE, FACT SHEET, AND NPDES PERMIT (USEPA)

C	SECTION 10/404 PERMIT (USCOE) (NONE PROVIDED)

D	FDER CONDITIONS OF CERTIFICATION

E	FLORIDA PUBLIC SERVICE COMMISSION FINAL ORDER

F	FLORIDA DEPARTMENT OF COMMUNITY AFFAIRS, FINAL REPORT

G	ST. JOHNS RIVER WATER MANAGEMENT DISTRICT, FINAL

REPORT

H	JACKSONVILLE, BIO - ENVIRONMENTAL SERVICES DIVISION REPORT

I	THE CEDAR BAY COGENERATION PROJECT - EROSION AND SEDIMENTATION

CONTROL PLAN

J	THE CEDAR BAY COGENERATION PROJECT SITE CERTIFICATION

APPLICATION, ENVIRONMENTAL IMPACT DOCUMENT AND AMENDMENTS
(INCORPORATED BY REFERENCE)

K	GLOSSARY

L	AIR RESOURCES

ix

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1

2

3

4

5

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

1

2

LIST OF TABLES

Page

Major Resource Requirements of the CBCP	2-12

Long-Term Forecast Conservation Programs	2-44

Power Supply Alternatives - Summary of Advantages 2-48 and 2-49
and Disadvantages

Solar Water Heating Units-Assumptions and	2-52
Calculations

Power Supply Alternatives - Summary of Economic	2-56
Analysis

Federal and Florida Ambient Air Quality Standards	3-6

PSD Class I and Class II Air Quality Increments	3-7

Water Quality Criteria	3-11	thru 3-14

Summary of CBCP Wastewater Discharges	3-17

State and Federal Groundwater Quality Criteria	3-24

Population Estimates for Duval County, Florida	3-35

Population Projections for 1988 and 1990	3-36

Employment Trends in Duval County, Florida	3-38

Household Income in Duval County, Florida	3-39

Projected Household Population and Dwelling Units	3-42
for Duval County, Florida

Existing Land Use Acreage - Northeast Florida Region	3-47

Summary of Land Use Existing in 1985 in the Area	3-48
Surrounding the CBCP

Existing Noise Levels	3-56

Death Rates Per 100,000 Population For Selected	3-63
Causes During 1978

Mortality Rates for Lung Cancer	3-64

Criteria for Estimating Potential Impacts	4-2	and 4-3

On Resources

Significant and Net Emission Rates	4-10

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LIST OF TABLES
(Cont'd)

Page

Table 4-3	Stack Parameters and Emission Rates	4-11

Table 4-4	Maximum Air Quality Impacts Versus the de minimus	4-12

Ambient Levels

Table 4-5	Comparison of Total Impacts with the AAQS	4-13

Table 4-6	Wastewater Effluent Concentration	4-38

Table 6-1	Power Supply Alternatives - Summary of Environmental	6-3

Impacts During Construction/Installation

Table 6-2	Power Supply Alternatives - Summary of Environmental	6-4

Impacts During Operations

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LIST OF FIGURES

Figure 2-1	Site Location

Figure 2-2	Railroad Location Plan

Figure 3-1 Locations of Major Emission Sources and Monitoring
Sites

Figure 3-2	Regionally Signficant Roadways and Railroads

Figure 3-3 Noise Monitoring Locations

Page
2-5

2-30

3-4

3-53
3-57

xii

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AAQS

AES-CB

AREA

As

B

BACT

Be

BOD

Btu

Btu/h

Btu/KWh

CAA

CAAA

CBCP

Cd

CFB

CFR

cfs

CO

COD

COM

CWA

dBA

ECFRPC

EID

EIS

ERA

ESP

F

FAA
FAC

FAWPCA
FCG

FCREPA
FDA

LIST OF ACRONYMS AND ABBREVIATIONS

Ambient Air Quality Standards

Applied Energy Services Cedar Bay, Inc.

American Railroad Engineering Association

Arsenic

Boron

Best Available Control Technology
Beryllium

Biochemical Oxygen Demand
British thermal unit
British thermal unit per hour

British thermal unit of energy required to produce 1 kilowatt-hour
of electricity

Clean Air Act

Clean Air Act Amendments'

Cedar Bay Cogeneration Project

Cadmium

Circulating Fluidized Bed
Code of Federal Regulations
Cubic feet per second
Carbon Monoxide
Chemical Oxygen Demand
Coal-Oil Mixture
Clean Water Act
Decibels (A-weighted)

The Eastern Central Florida Regional Planning Commission

Environmental Information Document

Environmental Impact Statement

The Economic Regulatory Administration

Electrostatic Precipitator

Degrees Fahrenheit

The Federal Aviation Administration

Florida Administrative Code

The Florida Air and Water Pollution Control Act
The Florida Electric Power Coordinating Group
The Florida Committee on Rare & Endangered Plants & Animals
The Florida Department of Agriculture

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LIST OF ACRONYMS AND ABBREVIATIONS
(Cont'd.)

FDS DHR	The Florida Department of State, Division of Historical Resources

FDAHR	The Florida Division of Archives, History and Records

FDCA	The Florida Department of Community Affairs

FDER	The Florida Department of Environmental Regulation

FDOT	The Florida Department of Transportation

FECL	The Florida East Coast Line

FEECA	Florida Energy Efficiency and Conservation Act

FEPPSA	Florida Electrical Power Plant Siting Act (also referred to as the
the Siting Act)

FERC	The Federal Energy Regulatory Commission

FGD	Flue Gas Desulfurization

FGFWFC	The Florida Game and Fresh Water Fish Commission

F1	Fluoride

FPC	The Florida Power Corporation

FP&L	The Florida Power & Light Company

FPSC	The Florida Public Service Commission

F.S.	Florida Statutes

Fuel Use	Federal Power Plant and Industrial Fuel Use Act of 1978
Act

g	Grams

GEP	Good Engineering Practice

GU	Government Use

gpd	Gallons per day

gpm	Gallons per minute

GWh	Gigawatts - hours = one billion watt-hours

HC	Hydrocarbons

HC1	Hydrochloric acid

Hg	Mercury

HRSG	Heat recovery steam generators

H2SO4	Sulfuric Acid

IH	Industrial Heavy Zone

ISCST	Industrial Source Complex Short Term air pollutant dispersion model

IW	Industrial Waterfront Zone

IWTS	Industrial Wastewater Treatment System

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LIST OF ACRONYMS AND ABBREVIATIONS

(Cont'd.)

JAPB	The Jacksonville Area Planning Board

JPD	The Jacksonville Planning Department

JEA	The Jacksonville Electric Authority

Km	Kilometers (1 Km = 0.6214 mile)

KRB	Kraft Recovery Boiler

kV	Kilovolt = one thousand volts

KWh	Kilowatt hours = one thousand watt-hours

lb/hr	Pounds per hour

lb/MBtu	Pounds per million British thermal units

LC50	Lethal concentration of a pollutant at which 50% of the test
population die in 96 hours

LWBZ	Lower water bearing zone, refers to the Oldsmar Limestone
Stratigraphic Unit of the Floridan Aquifer System

mgd	Million gallons per day

mg/1	Milligrams per liter (~ parts per million)

mg/m^	Milligrams per cubic meter

Mo	Molybdenum

MW	Megawatts

MWh	Megawatt hour = one million watt-hours

NAAQS	National Ambient Air Quality Standards

NDP	North District Plan

NEA	National Energy Act of 1978

NEPA	National Environmental Policy Act of 1969

N0x,N02	Nitrogen Oxides, Nitrogen Dioxide

NPDES	National Pollution Discharge Elimination System

NSPS	New Source Performance Standards

OSN	NPDES Outfall Serial Number

Pb	Lead

POD	Point of Discharge

ppm	Parts per million (- milligrams per liter)

PSD	Prevention of Significant Deterioration

psig	Pounds per square inch gauge

PURPA	Public Utility Regulatory Policies Act of 1978

RDF	Refuse Derived Fuel

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LIST OF ACRONYMS AND ABBREVIATIONS

(Cont'd.)

SAR	State Analysis Report

SAR/EIS	State Analysis Report/Environmental Impact Statement

SCA/EID	Site Certification Application/Environmental Information Document

prepared by AES-CB

SCR	Selective Catalytic Reduction

SERC	Southeastern Electric Reliability Council

SHPO	State Historic Preservation Officier

SJRPP	The St. Johns River Power Park

SJRWMD	The St. Johns River Water Management District

SK	The Seminole-Kraft Corporation

Siting	Florida Electrical Power Plant Siting Act (see FEPPSA)

Act

SNCR	Selective Non-Catalytic Reduction

SO2, S0X	Sulfur dioxide, Sulfur Oxides

SOU	The Southern Company

TDS	Total Dissolved Solids

TRS	Total Reduced Sulfur

TSP	Total Suspended Particulates

TSS	Total Suspended Solids

TVA	The Tennessee Valley Authority

ug	Microgram

ug/m^	Micrograms per cubic meter

USCG	The U.S. Coast Guard

USCOE	The U.S. Corps of Engineers

USDOE	The U.S. Department of Energy

USFWS	The U.S. Fish and Wildlife Service

USGS	The U.S. Geological Survey

USEPA	The U.S. Environmental Protection Agency
(or EPA)

USSCS	The U.S. Department of Agriculture Soil Conservation Service

UWBZ	Upper water bearing zone, refers to the Ocala Group Stratigraphic
Unit of the Florida Aquifer System

VOC	Volatile Organic Compounds

WTP	Wastewater Treatment Plant

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CHAPTER 1
INTRODUCTION

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1.0 INTRODUCTION

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 burning coal and woodwaste, which will produce 225
MW of electricity for sale to Florida Power and Light Company (FP&L) and
640,000 lbs/hr of process steam for sale to the 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), the Florida Department of
Environmental Regulation (FDER), and other federal agencies for permits
necessary to operate and construct the proposed facility.

This document constitutes both the FDER Staff Analysis Report (SAR) and
the USEPA Environmental Impact Statement (EIS) prepared jointly by USEPA and
FDER for the proposed project. This chapter provides an introduction to the
project including: (1) a summary of USEPA and FDER responsibilities for the
SAR/EIS; (2) a discussion of other federal requirements relevant to the
proposed project; (3) a summary of the coordination conducted between the
USEPA and FDER during preparation of the SAR/EIS; (4) a description of the
background and need for the proposed project; and (5) a summary of the issues
to be addressed in the SAR/EIS.

1.1 USEPA AND FDER RESPONSIBILITY FOR THE SAR/EIS

1.1.1 USEPA Responsibility for the EIS

Under Section 511(c) of the Clean Water Act (CWA), USEPA must comply with
the National Environmental Policy Act of 1969 (NEPA) prior to issuance of a
New Source National Pollution Discharge Elimination System (NPDES) permit
(Note: A new source under the CAA is not subject to independent NEPA review).
NEPA requires federal agencies to prepare an EIS on every major Federal action
significantly affecting the quality of the human environment. In this

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particular case, USEPA has determined that the CBCP proposed by AES-CB is a
new source for which new source performance standards have been promulgated
(40 CFR 423.15) and that an EIS must be prepared.

1.1.2	FDER's Responsibility for the SAR

Under provisions of the Florida Electrical Power Plant Siting Act (Siting
Act, Chapter 403.501-519, F.S.), FDER must prepare an SAR upon which the
State's decision to license any new steam electric power plant will be made.
The purpose of the power plant siting program is to provide an efficient,
comprehensive, coordinated, one-stop permitting approach to the State evalua-
tion of electric power plant location and operation. In accordance with the
Siting Act, no construction or expansion of a new electrical power plant may
be initiated without site certification by the State. Following submittal of
FDER's recommendations regarding site certification, the final site
certification for all activities requiring State permits must be issued by the
Governor and the State Cabinet.

1.1.3	Memorandum of Understanding for Preparation of a Joint SAR/EIS
Document

In previous years, USEPA and FDER published separate reports to meet
their responsibilities under NEPA and the Siting Act. In 1980, a Memorandum
of Understanding was executed between USEPA and FDER whereby it was agreed
that a single document would be produced to serve both as the SAR and EIS and
that the two agencies would take steps to minimize duplication of effort and
to maximize cooperation of effort in the licensing of new power plants in
Florida. This joint document will meet the responsibilities of both agencies
and will be known as the Cedar Bay Cogeneration Project State Analysis
Report/Environmental Impact Statement (SAR/EIS).

The objectives of the SAR/EIS are as follows:

o to describe the need for the new generating station as determined by

~

the Florida Public Service Commission (FPSC);

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o to develop and evaluate all reasonable alternatives to the project;

o to fully describe the selected project and its resulting impacts; and

o to investigate and describe measures that could be taken to eliminate
or minimize identified adverse impacts.

1.2	OTHER FEDERAL REQUIREMENTS

Several other Federal and State requirements must also be met for the
complete licensing of the CBCP. These include Prevention of Significant
Deterioration (PSD) under the Clean Air Act (CAA); compliance with the
Endangered Species Act of 1973 (as amended); compliance with Executive Order
No. 11990 for protection of wetlands and Executive Order No. 11988 concerning
development in flood prone areas; and Federal Aviation Administration (FAA)
approval for emission stack heights.

1.3	COORDINATION BETWEEN USEPA AND FDER

Extensive coordination between the USEPA and FDER occurred during the
preparation of the SAR/EIS. This coordination consisted primarily of several
preliminary planning sessions and formal meetings between USEPA, its con-
sultants, and FDER. USEPA and FDER jointly sponsored the public scoping
meeting on January 24, 1989, in order to obtain input on key issues for
determining the scope of the project. Both agencies will also conduct public
hearings on the SAR/EIS. Additional coordination was also conducted via an
exchange of technical information concerning the proposed project. In
general, FDER took the responsibility of evaluating the environmental impacts
of the proposed project while USEPA was responsible for defining and evaluat-
ing the alternatives to the project and preparing the SAR/EIS. Through mutual
review of each output, FDER and USEPA satisfied the goals of the Memorandum of
Understanding by complying with each agency's responsibilities for permitting
while avoiding duplication of effort.

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1.4 BACKGROUND OF THE PROJECT

This section provides an overview of the proposed CBCP. Included are an
identification of the applicants and a history of tfie project.

1.4.1 Identification of the Applicants

The proposed project is a joint effort of AES-CB and SK. AES-CB is the
lead applicant for the necessary permits.

1.4.1.1	AES/Cedar Bay Incorporated

AES-CB is a wholly owned subsidiary of Applied Energy Services,
Inc., a privately held corporation that builds, owns and operates cogeneration
facilities that sell steam and electricity to industrial and utility
customers. AES Inc. currently operates 350 MW of capacity at three facilities
in California, Pennsylvania and Texas. Two more plants with a combined
capacity of 500 MW are under construction in Connecticut and Oklahoma. The
objective of AES-CB is to be a long-term, low cost, reliable supplier of
energy concentrating on innovative coal-burning technology.

1.4.1.2	Seminole Kraft Corporation

SK is a privately held corporation which owns and operates the SK
paper mill. The mill produces unbleached liner board and kraft paper and has
been in operation under SK since April 1987. Stone Container Corporation,
which owns 60 percent of SK common stock, has management responsibility for
the mill and buys all of the mill's output. The mill was operated for 33
years prior to ceasing operation in 1985 prior to being purchased by SK.

After rehabilitation and modernization the mill reopened in 1987 and now
employs approximately 350 people.

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1.4.2 History of the Project

The proposed project was developed after a series of extensive studies
conducted by AES-CB and SK. AES-CB was searching for a suitable cogeneration
site. SK was seeking to modernize the existing mill and to replace the
existing chemical recovery boiler to comply with new air emission limitations
on total reduced sulfur which is a significant source of odors.

1.4.3 Permit Applications

On November 14, 1988, AES-CB concurrently submitted an NPDES permit
application to USEPA and a SCA to FDER for the proposed cogeneration project
at the SK site. Several amendments to these documents were subsequently
filed. In response to these applications, USEPA began cooperative efforts
with the FDER to prepare the SCA/EIS in order to satisfy the legal
responsibilities of both agencies for licensing the New Source power plant. A
joint public scoping meeting was held in Jacksonville on January 24, 1989, to
solicit public input to the scoping of the SAR/EIS.

1.5 NEED FOR THE PROJECT

In the case of a new power plant in Florida, the determination of need
for the project is made by the Florida Public Service Commission (FPSC).
According to Sections 403.508 and 403.519, Florida Statutes a formal
Determination of Need must be made by the FPSC prior to certification of a
power plant subject to the Siting Act. This determination serves as the
report required of the PSC as part of the state power plant siting
proceedings.

The FPSC received the petition for determination of need as included in
the SCA on November 14, 1988, from AES-CB for the 225 MW fluidized bed
cogeneration facility. The 225 MW would be sold to Florida Power and Light
Company via transmission line interconnections through the Jacksonville
Electric Authority system. Section 403.519, Florida Statutes requires the
FPSC to consider the following criteria in making a determination of need for
the project:

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o Need for electric system reliability and integrity;
o Need for adequate electricity at reasonable cost;
o Whether the proposed plant is the most cost-effective

alternative available;
o Conservation measures taken by or reasonably available to
the applicant or its members which might mitigate the
need for the proposed plant; and
o Other matters within its jurisdiction which the PSC deems
relevant.

On April 24, 1989, the FPSC conducted a public hearing to determine the
need of the proposed CBCP. On June 30, 1989, the FPSC granted AES-CB and SK
their petition for Determination of Need in the FPSC Order No. 21491 (Docket
No. 881472-EQ). A copy of the order is attached and included herein as
^Appendix E.

The order stated that the cogeneration project is a qualifying facility
pursuant to FPSC Rule 25-17.083. The FPSC rules implementing the Federal
Energy Regulatory Commission's (FERC) regulations adopted under the Public
Utility Regulatory Policies Act (PURPA) define "qualifying facilities" as
cogenerators or small power producers. The order asserted that the criterion
for cost effectiveness was met without a description of alternatives and their
costs. It was stated that the CBCP was a qualifying facility pursuant to
their rules and that AES-CB has negotiated a contract with FP&L for the sale
of firm capacity and energy at less than the statewide avoided cost. This
being the case, the FPSC found the proposed facility "to be most
cost-effective alternative available". 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
FEECA are not germane to qualifying facility needs determinations."

It is recognized that the FPSC order satisfies the Commission's
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 (refer to Section 2.5)
and the alternative means of satisfying the need (refer to Section 2.8). For

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the purposes of demonstrating need for the project in this EIS, only the 225
MW CFB cogeneration facilities were addressed, since the generation from the
chemical recovery boiler only replaces existing internal generation and the 42
MW generation is below the 75 MW threshold in the Siting Act (Section 403.506
F.S.).

The need for the cogeneration facilities was stated in the SCA in three
(3) ways:

(1)	additional capacity is needed to provide reliable service to utility
customers by increasing Peninsular Florida's reserve margin;

(2)	use of coal-fired cogeneration facilities displaces the future
consumption of oil and natural gas from 1993 to 2025;

(3)	process steam is needed by SK for their papermaking process.

After evaluating relevant documents prepared by the FPSC and the 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 lb/hr of process steam for use by the SK paper
mill.

These needs are defined to be needs to be met during the period between
1996 and the year 2025. The year 1996 is selected as the implementation year
rather than the CBCP startup year (1993) because PP&L has stated in their Ten
Year Power Plant Site Plan (1989-1998) a significant power need by 1996 (2,894
MW). The system alternatives as presented in Section 2.8, Alternative Means

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of Satisfying the Need for the Project, were developed using these needs as
the basis.

1.6 ISSUES TO BE ADDRESSED IN THE SAR/EIS

Several key issues to be addressed in the SAR/EIS concerning the proposed
project were identified through internal agency review by USEPA and FDER and
as a result of the public scoping meeting held in Jacksonville on January 24,
1989. The following is a summary of these issues:

o Concern about the air quality impacts of plant emissions of sulfur

dioxide (S02), carbon dioxide (C02), oxides of nitrogen (NOx), total
reduced sulfur (TRS), and particulates (from coal, ash and limestone
handling).

o Effect of plant operation on ambient odor and air quality,
o Local weather patterns and cumulative effects on air

quality, acid rain and Greenhouse Effect,
o Concern about water quality impacts and recreational

fishing in the Broward River,
o Concern about the destruction of wetlands and

construction in the 100 year flood plain which might
violate the local comprehensive plan,
o Concern about consumption of groundwater and drawdown

impacts on private wells,
o Concern about waste disposal including disposal of lime
sludge.

o Concern about the noise and vibrations caused by rail
traffic, conveyor operation and plant operation and
construction.

o Concern about plant discharges and operation on Manatees.
o Concern about operation of the power plant if the paper

mill were too close,
o Concern about the plant's appearance, impacts of plant
lighting at night including the potential annoyance of
aircraft warning lights at night
o Concern about the interruption of boat traffic into the

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Broward River and potential conflict with the scheduled
improvements to Hecksher Drive and bridge replacement due
to the proposed coal conveyor.

Concern about the effects of increased truck, rail, and
barge traffic to the site.

Concern about the handling of coal, ash, and other dusty
materials on site.

Concern about the socioeconomic impact of the project
including effects on property values and tax rates.

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CHAPTER 2
ALTERNATIVES,
INCLUDING THE
PROPOSED PROJECT

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2.0 ALTERNATIVES, INCLUDING THE PROPOSED PROJECT

2.1 REGULATORY PREROGATIVES

In order for AES-CB to construct and operate a new cogeneration electric
power plant, the company must comply with a number of local, State, and
Federal laws, regulations and ordinances. The agencies primarily involved in
permitting activities are USEPA and FDER. The permitting alternatives
available to these agencies are outlined in the following sections.

2.1.1 Alternatives Available to USEPA

The alternatives available to the USEPA in accordance with its regulatory
and permitting authority pursuant to Section 402 of the CWA are to issue or to
deny the New Source NPDES Permit requested by AES-CB for CBCP discharges into
the St. Johns and Broward Rivers.

2.1.1.1 Issuance of the NPDES Permit

Issuance of the New Source NPDES Permit will allow the AES-CB to
construct and operate the CBCP; to add its pretreated construction dewatering
wastes to the SK once-through cooling water effluent; to add cooling tower and
boiler blowdown discharges to the existing SK discharge to the St. Johns
River; to add its industrial waste discharges after pretreatment to the SK
wastewater treatment system with eventual discharge to the St. Johns River;
and to discharge emergency overflows due to high rainfall runoff to the
Broward River up to the limits set forth in the permit (see Appendix B, Draft
NPDES Permit No. FL0041173). The issuance of the permit may be modified by
certain conditions which could require that additional monitoring and
reporting be undertaken during the operation of the plant in order to evaluate
the effectiveness of the pollution control systems. Such conditions will be
added to the permit if the environmental impacts of the construction and/or
operation of the plant require special mitigation practices and additional
monitoring and reporting.

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2.1.1.2 Denial of the NPDES Permit

If it is determined that the proposed CBCP discharges into the St.
Johns and Broward Rivers will not be in compliance with New Source Performance
Standards or water quality standards, USEPA would deny the New Source NPDES
permit. Furthermore, USEPA could deny the permit if environmental resources
such as endangered species, historic or archeological sites, wetlands, or
floodplains are significantly impacted and measures for mitigating the impacts
are unacceptable. The denial of the permit would be equivalent to the
No-Action Alternative and would result in not allowing the discharge of the
wastewater effluent to the St. Johns and Boward Rivers. If the permit is
denied by USEPA, AES-CB would have the options of redesigning the project,
including the pollution control facilities, to meet the water quality
standards and resubmitting the application; locating and evaluating another
site; or pursuing the No-Action Alternative.

2.1.2 Alternatives Available to FDER

The FDER administers the PSD permit program pursuant to the CAA and a
State wastewater discharge permit program under the Florida Air and Water
Pollution Control Act (FAWPCA) and also provides State 401 Certification
(under Section 401 of the CWA) of all Federally issued permits in Florida. In
the case of new power generating facilities, review and permitting under these
and other environmental programs in Florida have been coordinated into a
one-stop process pursuant to the Siting Act. Under the Siting Act, FDER
conducts a coordinated review for each New Source power plant project which
incorporates all State agency reviews. A final written report known as the
SAR is prepared which includes FDER recommendation(s) concerning final State
site certification of the project. The SAR contains: (1) reports from the
Department of Community Affairs (FDCA), the Public Service Commission (FPSC),
the Water Management District (SJRWMD), and other State agencies; (2) results
of studies of the project conducted by FDER; (3) a statement of compliance
with FDER rules; (4) Conditions of Site and 401 Certifications; and (5) a
recommendation for final action.

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2.1.2.1 PSD Permit

The CAAA require that a PSD permit be secured for the CBCP from the
FDER before construction begins. New Source Performance Standards (NSPS) and
Best Available Control Technologies (BACT) must be met for the emission of air
pollutants. FDER has given tentative approval to the PSD permit application
for the CBCP, but has not issued the permit and maintains the right to deny
the permit based on final review. The final determination will not be made
until after the site certification public hearing. Should FDER recommend
denial of the permit, AES-CB would be given the opportunity to reduce facility
emissions or to make efforts to reduce emissions from other facilities to
reduce projected impacts and meet the goals of the CAAA which relate to PSD.
Further, the PSD permit and the power plant site certification can not be
issued if the National Ambient Air Quality Standards (NAAQS) are predicted to
be exceeded in the impact area of the project. If the NAAQS for any criteria
pollutant are exceeded or if a significant increase in the level of a
pollutant in a non-attainment area should occur as a result of the operation
of the facility, the applicant would be given the opportunity to mitigate
those impacts.

2.1.2.2 State Site and 401 Certifications

The final State Site Certification of a power plant is issued by FDER.
This certification represents the final State approval for all State permitted
activities of the project and may mandate specific requirements pursuant to
compliance with various State standards and regulations. Under the
certification process, the alternatives available to FDER pursuant to the
Siting Act are to recommend certification of the project as proposed,
certification of the project with revisions, or denial of certification. The
ramifications of certification or denial of certification would be similar to
those described for issuance or denial of the NPDES permit described in
Section 2.1.1

2.1.3 Alternatives Available to Other Permitting Agencies

The Florida Public Service Commission (FPSC), the Florida Department of
Community Affairs (FDCA), and the St. Johns River Water Management District

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(SJRWMD) are required by statute or rule to prepare reports on the application
for site certification on matters within their jurisdiction. Copies of these
reports are provided in Appendices E, F, and G. Initially AES-CB proposed the
use of a coal conveyor and its construction in U.S. waters but has deleted it
from the application, subsequently the U.S. Coast Guard (USCG) and the U.S.
Corps of Engineers (USCOE) no longer have permitting functions for the
project. Copies of the SCA were also sent to the following State, regional,
and municipal agencies with a request for comments:

o Florida Department of Agricultural and Consumer Services
o Florida Department of Commerce
o Florida Department of Transportation
o Florida Department of Natural Resources

o Florida Department of Health and Rehabilitative Services
o Florida Department of State, Division of Historical Resources
o Florida Game and Fresh Water Fish Commission
o Northeast Florida Regional Planning Council
o Jacksonville Area Planning Board

o Jacksonville Department of Health, Welfare and Bio - Environmental
Services

2.2 THE APPLICANT'S PROPOSED PROJECT

AES-CB proposes to construct and operate a new CFB 225 MU stream electric
generating station, which will also produce 640,000 lb/hr of process steam,
approximately seven miles north-northeast of downtown Jacksonville in Duval
County, Florida. The site for the proposed power project, including its
associated transmission and railroad unloading facilities, are described in
this section. The reader is referred to the applicant's Site Certification
Application/Environmental Information Document (SCA/EID) for more detailed
information.

2.2.1 The Project Site

It is proposed that a new 225 MW coal burning, CFB steam electric power
cogeneration facility be constructed on the site of the existing SK paper mill
in northern Duval County (refer to Figure 2-1). The site is owned by SK. The

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3

2000



1000

2000

Sella in Fnt

SITE LOCATION

FIGURE 2-1

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total existing SK paper mill site consists of 425 acres. Heckscher Drive
forms the southern boundary of the SK paper mill site. Eastport Road bisects
the SK paper mill property from north to south before merging with Heckscher
Drive.

The CBCP will occupy approximately 35 acres at the site and is to be
located west of the existing SK paper mill power plant and east of the Broward
River and the SK paper mill lime settling ponds. The area to be occupied by
the CBCP is currently used for storage of lime mud from the mill and
construction debris. An oil tank is located south of the CBCP site and a rail
yard is located to the north and west of the CBCP site. Due to previous
disturbances, there is little vegetation on site. Most of the existing
vegetation is mostly grasses, weeds and shrubs.

2.2.2	Plant Orientation and Appearance

CBCP will consist of three 75 MW CFB boilers, a single steam turbine
driven electrical generator, steam pipelines to supply the SK papermill,
mechanical draft cooling tower, coal handling facilities, coal and limestone
storage facilities, stormwater runoff control ponds and a 138 KV transmission
line to transfer the power from the plant to the JEA and FPL power network
systems. CBCP will blend in with the profile of the existing SK paper mill
with the exception of the exhaust stacks. CBCP will be newer and more modern
looking than the existing SK paper mill. CBCP will be located west of the
existing SK paper mill. The mechanical draft cooling tower array will be
located near the center of the CBCP plant area. Existing vegetation along the
Broward River will provide a partial screen for the plant facilities.

2.2.3	Power Generation System

CBCP will employ a single steam turbine-driven electrical generator using
steam produced by the three CFB boilers. The boilers will produce steam at
1800 psig for the double automatic extraction condensing turbine generator.
This system will produce 225 MW for sale as well as electricity for operation
of CBCP and 640,000 lb/h of 175 psig and 75 psig steam for sale to the SK
paper mill.

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2.2.4 Fuel Transportation and Handling

CBCP will burn approximately 1.1 million tons of coal per year. The coal
is proposed to be delivered to the site by train using the existing CSX
Railroad lines. Two (2) of the CFB boilers will also be designed to burn wood
waste from the SK paper mill. It is estimated that 198,000 tons per year of
wood waste could be burned. The railcar unloading system will employ an
enclosed bottom dumping type facility.

The bottom dumping facility will unload coal by positioning slow moving
cars over a receiving hopper and opening the railcar hopper doors to drop the
coal. Cars will be unloaded at a rate of 6 to 15 cars per hour.

The coal stockout system for rail car unloading will consist of an
automatically loaded conveyor which moves the coal from the receiving hopper
to the coal storage lowering well. Mobile equipment will be used to move the
coal from the lowering well to the lined storage area. The coal storage area
is to be located south of the the steam generation building. It is designed
to hold 105,000 tons of coal which is approximately a 30 day supply.

2.2.5 Air Emission Control System

AES-CB proposes to incorporate air pollution control equipment into their
facilities to control emissions of SOx, NOx, TSP (fly ash), CO, hydrocarbons,
fugitive dust, and TRS. Other trace pollutants will be removed from plant
emissions along with the major criteria pollutants. All air pollution control
systems are designed to meet NSPS and the BACT requirements of State and
Federal regulations.

2.2.5.1 TSP and Fugitive Dust Controls

TSP from the CFB boilers will be controlled by a fabric filter
system. The smelt dissolving tank emissions will be controlled by a wet
scrubber. Fugitive particulates will also be generated by the dissolved and
suspended solids in the cooling tower. TSP in the cooling tower drift will be

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controlled by the use of drift eliminators and by limiting the cycles of
concentration in the cooling system. Drift, as used in this document, is
defined in the Glossary (Appendix K).

2.2.5.2	SOx Controls

The coal will be burned within a fluidized bed of ash (bed ash).
SOx will be controlled by adsorption or limestone injected into the CFB.
Combustion within the fluidized bed places the SOx in direct contact with
calcium in the limestone. The chemical reaction between SOx and calcium
effectively removes the SOx from the exhaust gases.

2.2.5.3	Control of other Boiler Emissions

Emissions of NOx from the CFB boilers will be controlled by their
design and operation controls. Combustion of coal in a fluidized bed occurs at
temperatures low enough to reduce the amount of NOx formation significantly
when compared to a conventional coal fired boiler. CO, VOC, and Toxic Organic
Compounds from the CFB boilers will also be controlled by combustion controls.

2.2.5.4	Fugitive Dust

Fugitive dust will be produced by a number of sources including the
coal handling, limestone handling, flyash handling and the FGD waste handling
and disposal systems. Controls for these sources of particulates are planned
as follows:

o Coal Handling. Fugitive dust will be controlled by
different methods at each point in the coal handling
system. Wetting agents (90-99% efficient) will be used
on the various coal piles; fabric filters (99.9%
efficient) will be used at conveyor transfer points;
water spray systems (97% efficient) will be used at the
stacker reclaimer and coal unloading area. Conveying
systems will be enclosed.

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o Limestone Handling. Dust from unloading rail cars of
limestone and for handling of limestone by mobile
equipment will be suppressed with water sprays. Lime-
stone will be transported on enclosed conveyors where
fugitive dust at transfer points will be controlled by
fabric filters.

o Fly Ash and Spent Limestone Handling. A covered conveyor
with fabric dust collectors will be used to control
fugitive dust from transporting ash from storage silos to
rail cars in dry form. Water sprays will be used to
control dust from loading pellets into trucks whenever
rail removal of ash is not used.

2.2.6	Cooline System

CBCP waste heat from condenser and auxiliary equipment cooling will be
rejected to the atmosphere by a recirculating cooling water system using
mechanical draft cooling towers. The cooling towers will be rectangular,
mechanical draft, counter flow towers utilizing 200,000 gpm of circulating
water as a cooling fluid. A counter flow or recirculating cooling tower, as
used in this document, is defined in the Glossary (Appendix K). The cooling
tower will require an estimated 2,883 gpm of makeup water to replace the 2250
gpm of water lost to evaporation and the 633 gpm of cooling tower blowdown.
Cooling tower blowdown will be discharged from the cold side of the cooling
tower to maintain the chemical concentration of the cooling water at levels
that will not cause formation of excessive scale to inhibit heat transfer
efficiency. The cooling tower will recycle the cooling water approximately
4.6 times prior to blowdown which concentrates the pollutants. The maximum
discharge temperature of cooling tower blowdown is expected to be 96° F.

2.2.7	Wastewater Treatment Systems

Wastewater from 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 sources such as
ion exchange water treatment systems, water treatment evaporator blowdown,

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laboratory and sampling streams, floor drains, cooling tower basin cleaning
wastes and blowdown from recirculating house service water systems. These
discharges will be regulated according to NPDES permit No. FL0041173 (Appendix
B). The receiving waters include the St. Johns River during construction (OSN
003, 005, and 008) and operation (OSN 001, 002, 003, 004, 006, 007 and 008)
with emergency overflow discharges to the Broward River (OSN 003 and 008).
All waste effluents to the St. Johns River will be via the SK discharge
diffuser system (NPDES No. FL0000400). Table 3-4 of the next chapter
summarizes the type and sources of the wastewater discharges. For a sketch
showing the location of the discharges, see Attachments A and B of NPDES
permit No. FL0041173 (Appendix B). Detailed descriptions of the discharges
can be found in Section 4.3 and Appendix B.

During construction, various techniques including sedimentation will be
used to control construction related runoff (OSN 003 and 008). A copy of the
applicant's proposed Erosion and Sediment Control (E&SC) Plan is provided in
Appendix I. The E&SC Plan as submitted is inadequate. Revision of the Plan
is necessary before it is consistent with requirements of Part III. D of the
Draft NPDES permit (Appendix B) and can be considered an acceptable plan. The
revised and tentatively approved plan will be included in the FEIS. A list of
needed revisions is given in Appendix I.

A physical/chemical treatment system will be required for plant
dewatering waste (OSN 005). Treatment by this system is needed to reduce,
copper, zinc, and other metals. However, details on this treatment system
have not as yet been provided by the applicant. A thorough description of
this system will need to be included in the FEIS.

During operation, recirculating cooling towers (with dechlorination) will
be used to treat waste heat (OSN 002), sedimentation for stormwater runoff
(OSN 003), reuse for boiler blowdown (OSN 004), neutralization and/or oil
removal as pretreatment followed by further treatment in the SK IWTS for low
volume wastes (OSN 006), offsite disposal and/or physical/chemical treatment
for metal cleaning wastes (OSN 007), and sedimentation followed by further
treatment in the SK IWTS for coal, limestone, and ash storage area runoff (OSN
008). Plant sewage will be treated in the SK domestic waste treatment plant.

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A description of the treatment system for metal cleaning wastes (both
chemical and nonchemical) has not as yet been provided by the applicant. This
treatment system will need to be described in the FEIS.

2.2.8	Solid Waste Handling and Disposal

Solid waste generated by the CBCP will consist primarily of fly ash and
bed ash (including spent limestone). This material is to be disposed of by
the coal supplier at an approved disposal location outside of the State of
Florida or sold to the building materials industry. The quantities of the
waste produced will depend on the properties of the coal and limestone used in
the combustion process. Fly ash will be conveyed to storage silos by a vacuum
transport system. Bed ash will be conveyed to a storage hopper by mechanical
conveyors and from the storage hopper to silo by a vacuum system.

Ash from the storage silos may be sent directly to railcars in a dry
form, or ash may be formed into pellets by mixing it with water and allowing
it to cure. After curing, the pelletized ash would be stored before removal
by truck or rail. 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.

2.2.9	Transmission Facilities

An interconnection from CBCP to JEA electric power grid will be made by
constructing a 138 KV transmission line from CBCP to JEA Eastport substation.
The Eastport substation is located directly southeast and adjacent to the SK.
Since the interconnecting transmission line will be constructed over already
disturbed SK property or on JEA right-of-way, the environmental impacts will
be slight.

2.2.10	Resource Requirements

The major resource requirements of the, CBCP on a yearly and lifetime
basis are summarized in Table 2-1. Coal will be burned in the boilers along
with wood waste. No. 2 fuel oil will be used for boiler startup. Limestone
will be used for adsorption of SOx as the coal is burned. Consumptive uses of
groundwater include boiler makeup, cooling tower makeup, and potable water.
There will be no consumptive use of surface water.

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Table 2-1

Major Resource Requirements of the CBCP

	Resource			Yearly			Lifetime (5)

Coal (1)	1.105 tons	33.15 Mtons

Wood Waste (2)	0.198 Mtons	5.94 Mtons

Fuel Oil (3)	0.160 MGals	4.80 MGals

Limestone	0.100 Mtons	3.00 Mtons

Groundwater (4)	1.99 BGals	59.70 BGals

(1)	Based on a coal consumption rate of 145 tons per hour, a design capacity
factor of 87 percent and maximum coal properties of 15% ash and 3.3%
sulfur.

(2)	Based on operating with a combination of coal and wood waste, a
consumption rate for steam generation of 8 tons per hour and the
operation of 3 steam generators. Also assumes availability of sufficient
fuel with a heating value of 6,791 BTU/lb.

(3)	Assumes that each of the 3 steam generators will experience 5 cold or 12
hot startups per year.

(4)	Based on average daily use of 5.44 mgd for 365 days a year.

(5)	Based on a service life of 30 years

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2.3 SITE ALTERNATIVES

As stated by AES-CP in the SCA, 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
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 NDP, prepared by the planning
department of the City of Jacksonville. The NDP requires that every effort be
made to reduce or mitigate the negative environmental impacts of the project.
Potential adverse impacts of the proposed CBCP are specified in Chapter 5 of
this document. Chapter 5 also identifies available mitigative measures.

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.

Site design alternatives are defined in Section 2.4 for the respective
CBCP systems and sites for alternative power generating sources are defined in
Section 2.8 for the alternative means of satisfying need for the project.

2.4 PLANT SYSTEMS ALTERNATIVES

Within the framework of the 225 MW cogeneration facility being proposed,
alternatives were developed for evaluation for every major aspect of plant
design for which some flexibility existed except steam generation. The
alternative processes presented in this section are limited to the
environmental controls which are required to meet standards and those plant
units with designs which are of environmental concern. For each system, an
attempt was made to describe alternatives which merit serious consideration
and to describe the advantages and disadvantages of each.

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2.4.1 Cooling Systems

2.4.1.1 Cooling Facilities

Wast'fe heat from the condensation of turbine exhaust steam is
disposed into the atmosphere by a heat rejection system referred to here as a
cooling system. The term "cooling tower" as used in this document is defined
in the Glossary (Appendix K). The water used to produce steam is ultra pure
treated water. This costly to produce raw material must be reclaimed for
reuse. The low pressure, low temperature steam which has been used to drive
the turbine must be condensed to water, so that it can be pumped back to the
boiler where it is reheated to produce high pressure, high temperature steam.
AES-CB has proposed the use of wooden (treated blue spruce), rectangular
mechanical draft towers. A number of alternative cooling systems exist.

Below is a list of alternatives considered along with comments from the
initial screening of the alternatives.

2.4.1.1.1	Once-Through Cooling

A once-through cooling system would use cooling water from the
Broward River or the St. Johns River and pump it through a condenser to
condense the turbine exhaust steam. The heated water would then be-discharged
back to the source river. A cooling pond could be used as an intermediate
discharge point. The once-through cooling system was eliminated from use in

I

this project because it was determined that it would not be able to meet
Florida's Water Quality Standards requirements. Also the large land area
requirements ^nd high capital cost of cooling ponds make the use of ponds
-undesirable.

2.4.1.1.2	Wet Natural Draft Cooling Towers

Natural draft cooling towers use a large chimney to create an
upward draft to pull air through the tower fill. Circulating water is pumped
to the fill eievation of the tower and allowed to fall. Water is distributed
over the fill and heat exchange occurs by evaporation and convection. The
density difference between the warm air inside the tower and the cooler air
outside creates a "natural draft" and airflow occurs without using mechanical

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draft fans. Natural draft cooling towers generally are higher in capital cost
but lower in operating cost and energy consumption than rectangular and round
mechanical draft cooling towers. This can result in natural draft towers
having a slightly lower annualized equivalent cost. From an environmental
perspective, natural draft towers exhibit a higher vapor plume rise and a
longer drift. Because of their greater height, however, the vapor plume
reaches the ground at a distance and the potential for ground fogging as
compared to mechanical draft towers is reduced. This alternative is
eliminated because of its high capital costs and large size.

2.4.1.1.3	Mechanical Draft Cooling Towers

Mechanical draft towers use large fans to pull air through the
tower fill. Water is distributed over the fill, and heat exchange takes place
by evaporation and convection. Since airflow is produced by mechanical fans,
the structure of the tower is smaller than a natural draft tower. Sub-
sequently, initial capital costs are lower but operating costs and energy
consumption are higher. Two types of mechanical draft towers are used in the
power generation industry, rectangular towers built of treated wood and round
or rectangle towers built of concrete. The rectangular towers generally have
a lower initial capital cost and a lower energy consumption rate than round
towers. Wooden towers have a lower initial capital cost than concrete towers,
but higher operation and maintenance costs. AES-CB proposes to use wooden
towers. Operating costs are comparable. Round towers have a slightly better
drifting characteristic with lower fogging potential.

2.4.1.1.4	Dry and Wet-Dry Cooling Towers

Dry cooling towers are very advantageous when water supplies
for cooling are limited because the system does not require makeup water to
replace water lost by evaporation. The system dissipates heat from the
condenser by conduction and convection directly to the atmosphere .via banks of
metal finned-tube heat exchangers. These cooling towers are approximately an
order of magnitude more expensive than wet towers and required a very large
physical structure.

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Wet-dry cooling towers use a combination of dry and evaporative
cooling. The resulting air leaving the tower is in a warm but unsaturated
condition. The reduced evaporation minimizes makeup requirements. These
cooling towers are also more expensive than the traditional wet cooling towers
and have been excluded because of the high costs and relatively large land
area requirements.

2.4.1.2 Cooling Water Sources

AES-CB proposes to use existing SK water supply wells from the
Floridan aquifer to supply the water needs of the CBCP. These wells are
approximately 1,400 feet deep, and are located on the SK site. The water mass
balance chart prepared by AES-CB indicates that the cooling towers will
require approximately 4.147 MGD (estimated annual average for 100 percent
load) of water as make-up. This includes 3.990 MGD of groundwater and 0.157
MGD of boiler blowdown. Of this make-up, 3.236 MGD is expected to evaporate
in the towers and 0.911 MGD will be disposed of as cooling tower blowdown to
the St. Johns River. The following sections describe alternatives to the
ground- water source,

2.4.1.2.1	Surface Water

Use of surface water from the Broward River or the St. Johns
River would require the construction of new intake facilities. In addition,
the brackish waters would require treatment to meet the water quality
requirements of the cooling towers. This alternative water source was
eliminated due to costs, environmental impacts (impingement and entrainment of
aquatic organisms) and possible impacts of salt water drift on SK and CBCP
facilities.

2.4.1.2.2	Recycled Wastewater
Recycling of CBCP Wastewaters

The CBCP water mass balance indicates that a total of 1.147 MGD
of wastewater will be discharged from the CBCP facilities during operation.
Of this flow 0.911 MGD is cooling tower blowdown; 0.229 MGD is sanitary

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treatment plant effluent, and 0.007 MGD is storrawater runoff collected from
the roof and yard areas. This volume rate would only meet 28% of the cooling
towers needs and therefore require a supplemental water source. In addition,
recycling would require extensive treatment to meet the water quality
requirements of the cooling towers.

Recycling of Reclaimed Municipal Wastewaters

SJRWMD has required, as a condition for permit approval, AES to
pursue the use of reclaimed water from the City of Jacksonville to supply the
non-potable cooling tower needs. The City of Jacksonville has recently
completed a SJRWMD-required Reuse Feasibility Study as part of a separate
permit application. One alternative identified in the report, diverting flow
from the Buckman WWTP to the District II (Cedar Bay) WWTP and increasing the
level of treatment, could provide up to 10 MGD of reclaimed water to the CBCP.
AES has agreed to design the CBCP so that it will be capable of receiving
reclaimed water from the City of Jacksonville for use as cooling make-up
water.

EPA supports the SJRWMD's requirement that reclaimed municipal
wastewater be used for CBCP cooling tower needs in lieu of groundwater "from
the Floridan Aquifer. When the City of Jacksonville can provide treated
wastewater of suitable quality, this alternative should be implemented.

2.4.1.3 Cooling Water Discharge Alternatives

An existing outfall structure located in the St. Johns River is
currently used to discharge effluent from the SK mill. AES-CB proposes to
discharge 0.911 MGD of chlorinated and dechlorinated cooling tower blowdown
via this outfall. Since AES-CB proposes to use well water as its raw water
source, there will be no screened organisms or trash for disposal.

Alternatives to this discharge scenario are described below.

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2.4.1.3.1	Discharge to the Broward River

Discharge to the Broward River would require the construction
of a new outfall. In addition, an evaluation would need to be made to
determine the effect of the discharge on this smaller river. This evaluation
would include an analysis of the minimization of thermal plume entrainment,
thermal plume attraction, cold shock, salinity and biocidal and chemical
effects. This alternative was eliminated due to costs and adequacy of the SK
discharge system.

2.4.1.3.2	Recycle Cooling Water

The alternative is similar to the Cooling Water Source alterna-
tive described in Section 2.4.1.2.2. Not only could the 0.911 MGD of cooling
water be treated and recycled to the cooling towers, but it could also be
treated and recycled to the steam cycle and/or service water system of the
CBCP which use 1.385 MGD and 0.065 MGD of water, respectively. This
alternative was eliminated due to very high costs and the complexity of the
treatment system required.

2.4.2 Water System Alternatives

The water requirements of the CBCP are described in Section 2.2 and the
water system alternatives for the condenser cooling system, the primary water
use, are described in Section 2.4.1. This section analyzes the other
alternative water systems proposed for the CBCP which include water use for
potable water, general plant uses, fire water, and makeup to the steam cycle.

The proposed primary source of water for all systems of the CBCP is
groundwater from the Floridan aquifer. The groundwater used by the CBCP with
the exception of cooling tower usage, will be softened and filtered in the SK
pretreatment system.

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2.4.2.1 PoCable Water Systems

Potable water uses include water for drinking, washing and for
toilets. The annual average expected usage is 4,100 gpd based on an average
plant staff of 75 people and an average potable water requirement of 55
gallons per capita per day. This flow includes use at both the cogeneration
plant and the SK paper mill. Because of the high quality water needed for
potable water uses and the low volume of flow involved, no alternative to
groundwater use is proposed.

2.4.2.2	Makeup Demineralizer System

Other than cooling water, the major use of water in the CBCP will be
for demineralized water makeup to the boiler/turbine/condenser cycles.
Demineralized makeup water is required to replace water lost to SK process
steam uses, boiler blowdown, and miscellaneous steam losses.

An annual average of 1.385 MGD of water will be demineralized using
three ion exchange demineralizer trains. The resulting 0.147 MGD regenerate
waste stream will be routed to the neutralization basin for pH adjustment and
then to the SK WTP. The regenerant is not considered suitable for reuse
because of its high dissolved solids content. Because of the demand for high
quality water in the steam cycle, no alternatives to groundwater use are
proposed. A portion (1.263 MGD) of the steam produced for the SK mill
processes will be returned to the steam cycle for reuse after it is polished
using a powdered resin type condensate polishing system.

2.4.2.3	Other Water Uses

The fire protection system water requirements are negligible. Even
though groundwater is the source proposed, no alternatives are considered
here. High quality water is required to prevent corrosion and scaling in the
storage and distribution system.

65,000 gpd of treated groundwater is expected to be used in the
service water system which includes water for water seals, cleaning, and
flushing. No alternatives are provided for this water use.

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2.4.3 Wastewater Treatment Systems Alternatives

The CBCP will utilize the existing SK IWTS for final treatment of
demineralizer regeneration wastewater, condensate polisher regeneration
wastewater, metal cleaning wastes, miscellaneous wastewater, and coal,
limestone, and ash area runoff after pretreatment by CBCP. Stormwater runoff
from roofs and yard area will be diverted to a holding pond after which it
will be discharged along with the cooling tower blowdown and the SK IWTS
effluent into the St. Johns River.

A sand/gravel filter may be added to a holding pond for improved TSS,
silt and sediment removal. A sand/gravel filter consists of a mound of gravel
covered with sand within the holding pond. All water in the holding pond
flows through the sand/gravel filter to a perforated pipe. The "filtered"
water is then discharged. This relatively inexpensive alternative is strongly
recommended for the CBCP.

2.4.3.1 Sanitary, Plant Process, and Chemical Wastewater "Collection

Separate collection systems are proposed to collect chemical waste-
water and miscellaneous plant wastewater. Collected flows and their destina-
tions include the following:

o Miscellaneous flow drains will direct water service system

wastewater to an oil separator and then to the SK IWTS via OSN
006.

o All sanitary wastewater from the potable water system will be
.routed directly to the SK Sanitary WTP.

o Surface runoff from the coal, limestone, and ash storage areas
will be collected in the fuel storage area retention basin
(OSN008) and then routed to the SK IWTS. Emergency overflow
from high intensity' storms will be discharged to the Broward
River.

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o Regeneration wastewater from the demineralizer will be directed
to the neutralization basin after which it will be routed to
the SK IWTS via OSN 006.

o Wastewater from the condensate polisher will be routed directly
to the SK IWTS via OSN 006.

o Metal cleaning wastes (OSN 007) will be pretreated and
discharged to the SK IWTS via OSN 006.

o Effluent from the SK IWTS will be routed to the St. Johns
Rivers outfall.

o Surface runoff from the roof and yard drains will be directed
to the retention pond (OSN 003) after which it will be routed
to the St. Johns River outfall (OSN 001).

o Cooling tower blowdown (OSN 002) will be routed directly to the
St. Johns River outfall (OSN 001)

Alternatives to these conveyance systems would include possible
recycling of wastewater or independent treatment of wastewater flows.

2.4.3.2 SK Industrial Wastewater Treatment System

The existing facility consists of a clarifier followed by aeration
ponds. Wastewater from the CBCP routed to the WTP is expected to average
229,000 gpd of flow, 75 lb/day of suspended solids (SS), and 20 lb/day of
BOD5. Wet weather flow is expected to be 622,000 gpd. SK has agreed to
accept this waste to their treatment system without increase in limitations
for their discharge (NPDES FL0000400). Alternatives were not considered
because it has been determined that the SK IWTS can provide adequate treatment
for the additional flow.

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2.4.3.3 Treatment of Recirculating Cooling Water

Cooling water is to be treated with sulfuric acid and an organic
phosphate type scale inhibitor to control the scaling tendency of the
circulating water system. Also, intermittent shock chlorination will be used
to prevent biological fouling of the water. The blowdown will be dechlori-
nated prior to disposal via the St. Johns River outfall, using either sulfur
dioxide or sodium sulfite.

Chlorination is the industry standard for control of biological
fouling in cooling systems. Chlorine is an inexpensive and effective biocide.
It can be added to the recirculating cooling water either as gaseous chlorine,
solid calcium hypochlorite, or liquid sodium hypochlorite to form hypochlorous
acid and hypochlorite ions which are the effective biocides. In order to
control biological fouling, a sufficient concentration of residual chlorine
biocides must be maintained in the system for a long enough period of time
(typically 2 hours) to destroy microorganisms in the system. Total chlorine
residuals (TRC) in the form of free available chlorine and combined residual
oxidants remaining in the system are discharged in the system blowdown. The
toxic effects of chlorine residuals on the aquatic environment are of concern
and must be minimized by careful management of chlorine dosing or by using a
dechlorination unit. Alternatives to chlorination are bromochlorination and
ozonation as presented below.

2.4.3.3.1 Bromochlorination

The use of bromine chloride as a cooling system biocide is
relatively new. The bromine chloride hydrolosis in water to hypobromous acid
(an effective biocide) and hydrochloric acid. This hydrolysis results in a
lower level of residual chlorine and chloramines than does the hydrolosis of
chlorine. However, adequate toxicity data is not available for bromine
residuals on aquatic organisms and its use is eliminated for that reason.

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2.4.3.3.2 Ozonation

Ozone (O3) is one of the most powerful biocides known. It is
very effective and decomposes to oxygen after a short time in the water,
thereby improving water quality. However, ozonation has several drawbacks
including the need for expensive on-site production facilities (it cannot be
stored), corrosiveness to iron alloys and slightly less effectiveness than
chlorine on some biological slimes which foul cooling towers. There is no
operating experience with ozone for this purpose and the capital and O&M costs
are high. Ozone is extremely reative and not expected to be present in
effluant. This alternative is eliminated because of technical unknowns.

2.4.4 Air Pollution Control System

The evaluation of emission control alternatives with regard to energy,
environmental, engineering, and economic objectives is a requirement of the
Best Available Control Technology (BACT) portions of the applicable federal
Prevention of Significant Deterioration (PSD) regulations and their counter-
parts in the rules of the FDER (Chapter 17.2, FAC). PSD permit requirements
apply to the CBCP because the net emissions increase of at least one regulated
pollutant exceeds the "significant" levels defined by USEPA and FDER. AES-CB
proposes in the SCA that a CFB with limestone injection and combustion
controls, followed by a fabric filter, is BACT for the cogeneration plant.

The air pollution emission-generating components of the CBCP are the only
components to be considered in this SAR/EIS. This facility is to consist of
three (3) coal fired CFB boilers and various material handling operations.
The emission-generating components of the SK paper mill are not included in
this development of alternatives. The CFB is considered a
"concurrent-combustion emission-control process" technology. Much of the
sulfur is removed during combustion by a sorbent material, in this case
limestone. Also in this process nitrogen oxides (NOx) production is low
because of the relatively low temperature at which the combustion reaction
takes place.

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2.4.4.1 Particulate Control

A fabric filter is proposed as the particulate control unit follow-
ing the CFB boilers for limiting TSP emissions. An alternative to the use of
fabric filters is the use of electrostatic precipitators (ESP). ESP's tend to
have a higher capital cost than fabric filters, but this difference is
compensated with their lower operation and maintenance costs. Fabric filter
operation and maintenance costs tend to be higher as a result of filter
replacement costs and higher fuel costs required for operations. The use of
fabric filters as proposed by AES-CB in the SCA, though maybe more expensive,
is a desirable control method because of its high particulate control rate of
0.02 lb/MBTu as compared to the 0.03 lb/MBTu control rate of ESP's.

2.4.4.2	Sulfur Dioxide Control

TRS and SO2 is proposed to be controlled by proper boiler design and
combustion controls in the CFB boilers. The SCA summarizes the results of the
BACT analysis completed for the cogeneration facilities. The analysis
compared three CFB boilers (each providing 33 percent of the total capacity)
to a single full-capacity pulverized coal (PC) fired boiler. The SO2 removal
alternatives evaluated included the PC boiler followed by a wet limestone
scrubber system (designed for both 90 and 94 percent SO2 removal), and the PC
boiler followed by a lime spray dryer system (designed for 90 percent SO2
removal).

2.4.4.3	Alternative Controls for Other Emissions

Other emissions of concern include NOx, CO, VOC, and Pb. The ^\ES-CB
states in the SCA that CFB boilers have lower NOx emission levels than PC
boilers (0.36 lb/MBtu as compared to 0.40 lb/MBTu) with no air quality control
unit. It also stated that a CFB or a PC boiler should be capable of meeting a
CO emission rate of 0.19 lb/MBtu (CFB boiler) or 0.11 lb/MBtu (PC boiler)
while meeting previously discussed NOx and SO2 emission levels. To employ NOx
emission limiting techniques such as lower combustion temperatures and excess
combustion air are counterproductive relative to CO emissions because the
emission levels of NOx and CO are inversely related to each other.

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Alternatives to controlling NOx emissions after combustion include
selective catalytic reduction (SCR) and selective noncatalytic reduction
(Thermal DeNOx) control technologies. With regard to the technology being
proven, both SCR and SNCR have had operating experience in both Japan and
Europe. More recently, several facilities in California have been permitted
with SNCR. Compliance testing has indicated that one of the facilities which
is now operating (Corn Products) has passed its compliance test. Another
operating facility (Cogeneration National) has had trouble meeting the Nox
emission limitation while also maintaining compliance with the CO and SO2
emission requirements. This plant has continued with adjustments targeted at
achieving coincidental compliance.

Outside of California, the application of SNCR on CFBs is extremely
limited. A recent permit for the Panther Creek Partner facility (Carbon
County, Pennsylvania), however, determined that.BACT for the new CFB boilers
would be SNCR to achieve a N0X limit of 0.2 lb/MMbtu (one hour average).

The applicant has stated that SNCR systems emit various amine
compounds formed by unreacted ammonia which represents a potential adverse
human health effect. Although it has been demonstrated that ammonia slip does
occur, this does not indicate that the technology has not been proven. The
use of both SCR and SNCR as representing BACT is becoming more and more
prevalent for internal combustion engines, boilers and turbines.

EPA's recent BACT determinations for other facilities would tend to
support incorporation of SNCR as BACT for nitrogen oxides control for the
CBCP. The site is located in an area which is designated as being
nonattainment for ozone. Nitrogen oxides are known to be a precursor to
ozone.

Fugitive particulates will be generated by fuel handling, waste
handling, and salt drift from the cooling towers. Control measures for these
sources include coal pile wetting, enclosed conveyors, fabric filters at
transfer points, and mist eliminators on the cooling towers.

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2.4.5 Solid Waste Management Alternatives

The combustion products to be generated by the CBCP include fly ash and
bed ash. The quantities of waste to be produced will depend on the properties
of the coal and limestone used in the combustion process. AES-CB estimates
that both the bed ash and the fly ash will be disposed of by the coal supplier
at an approved disposal location outside of the State of Florida or sold
within the building materials industry.

2.4.5.1 Bed Ash

AES-CB estimates that bed ash production will be approximately
88,000 tons per year. It is to be conveyed from the boiler ash coolers to a
storage hopper by mechanical ash conveyors. From the hopper, the bed ash will
be conveyed via a vacuum transport system to a silo.

As stated above, it is proposed that the coal supplier will dispose
of the bed ash outside of Florida or to the building materials industry. This
does not relieve AES-CB of the responsibility of assuring the adequacy of
disposal. Because no disposal means has yet been defined, alternatives are to
be considered including: (1) wet sluicing to a lined ash pond for disposal;
(2) wet sluicing to dewatering bins and landfill disposal; and (3) ^mechanical
ash removal with landfill disposal. The first alternative, wet sluicing to a
lined ash pond, is the industry standard. In this system, ash laden sluicing
water is routed from the ash hoppers to the pond where the ash settles out and
the water is recirculated back to the plant. The second alternative is
similar except that the ash is separated from the sluicing water in bins and
then trucked to a landfill for disposal. The third alternative accomplishes
simultaneous ash removal and dewatering by means of a conveyor system. The
ash is trucked from the conveyor discharge point to a landfill. This 'alter-
native requires less water and power than the other systems and is consistent
with the design of the CBCP. The major concern is the location of a landfill
that could receive the dry bed ash.

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2.4.5.2 Fly Ash

AES-CB estimates in the SCA that fly ash will be produced at a rate
of 354,000 tons per year. Most (336,000 tons per year) is to be collected
using a fabric filter after which it will be conveyed by an enclosed vacuum
transport system to a storage silo. Bag filters are proposed to control
fugitive dust emissions from the ash silo and vacuum system. Fly ash expected
to accumulate in the air heater hoppers (18,000 tons per year) will also be
conveyed to the silo via the vacuum transport system.

As is the case with bed ash, even though the SCA states that final
disposal is to be the responsibility of the coal supplier, alternative
disposal means must be defined.

Two fly ash disposal alternatives were considered: (1) wet sluicing
to an ash pond for disposal and (2) vacuum conveyance with landfill disposal.
Since the fly ash will be collected dry and sold if possible, it appears that
the first alternative would create an unnecessary wastewater stream. Further,
a complete recycle system would be required for the fly ash transport water
because proposed USEPA regulations prohibit any discharge of TSS and oil and
grease from the system. Because of dissolved solids buildup in the transport
water and associated scaling problems, a complete recycling system would be
expensive and difficult to operate. The second alternative requires the need
for a landfill site which can receive the dry fly ash.

2.4.5.3 Hazardous Waste

AES-CB states in the SCA that there will be no hazardous waste
produced by the CBCP. Demineralizer wastes, which can contain up to 10
percent sulfuric acid (H2SO4) or up to 5 percent sodium hydroxide (NaOH), will
be routed to the neutralization basin for pH adjustment. The neutralization
basin serves as an "elementary neutralization unit" allowing the cogeneration
plant an exemption from permitting as a hazardous waste facility. Further-
more, because the demineralizer wastes are not stored prior to pH adjustment,
they are not counted as generated hazardous waste, and the plant is therefore
not subject to regulation as a hazardous waste generator.

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Details on treatment systems proposed for the disposal of metal
cleaning wastes (both chemical and nonchemical) have not as yet been provided
by the applicant. A thorough description of these systems will have to be
submitted to determine whether hazardous wastes will be involved.

2.4.6 Materials Handling Systems Alternatives

2.4.6.1	Construction Materials and Equipment

AES-CB states in the SCA that construction materials and equipment
will be delivered to the site using existing roads and railroads. A new
access road is to be constructed on the mill site to provide access to the
construction areas from Eastport Road. Construction material is to be stored
in areas currently used to store lime mud, logs and debris which are located
north of the SK mill woodyard. Materials are to be unloaded and moved around
the site using portable cranes and trucks. Heavy items will be delivered via
rail and handled using special rigging. Pollution control measures are to
include runoff detention ponds to hold and clarify storm runoff prior to
release to natural drainage. Main roads at the site are to be gravel surfaced
and treated with dust palliative to reduce dust. Also, water sprays will be
used, as required, to control dust due to traffic.

2.4.6.2	Limestone Handling

Limestone handling consists of delivery, unloading, stockout,
reclaiming, preparation, and storage. Fugitive dust control from the handling
processes is to be accomplished by fabric filter dust collectors. The lime-
stone belt conveyors and feeders are to have covers over the belt to control
fugitive dust. If limestone is delivered by rail, a lowering well is to be
used for limestone stockout. Water sprays are proposed to be used to control
dust from mobile equipment operators. Storm runoff from the storage area is
to be collected and routed to a lined retention basin.

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2.4.6.3 Ash Handling

Ash generation and handling is described in Sections 2.4.5.1 and
2.4.5.2. Up to seven (7) days of dry ash pellet (9,700 tons) may be stored
on-site in an area that is to be lined with a synthetic liner. The liner is
to be protected with a soil cover and storm runoff will be collected and
diverted to the lined retention basin. Removal of ash pellets or silo-stored
ash from the site will use either closed truck or railcars. Water sprays will
be used, as required, to reduce fugitive dust from pellet handling and fabric
filters will be used to collect dust from dry ash handling.

2.4.6.4 Coal Delivery and Handling

Coal is to be delivered via rail. The CSX Railroad currently serves
the SK mill site. The line from which the mill spur branches is currently
used for unit train coal delivery to the JEA St. Johns Power Park a few miles
east of the mill site. This line is not expected to need upgrading for the
proposed CBCP. Modifications will be necessary to the mill spur. In general,
the CBCP will require one parallel rail line placed to the west of the
existing rail sidings located north of the plant site a new tract placed east
of the single causeway track, and a double track extension along the southern
portion of the site. The rail corridor and extension layout are shown in
Figure 2-2.

AES also considered a coal delivery alternative via a coal conveyor
across the Broward River. This alternative included a coal marine terminal
located south of the central plant area across the Broward River on Drummond
Point. The conveyor was to start at the barge unloading dock at the terminal
and run north for about 4,000 feet to the coal stockout pile. It was designed
to be an enclosed belt type conveyor with covers and full length continuous
dock plate. It would have been supported by a structural steel gallery with a
vertical clearance beneath the gallery of 13 feet. The spans were to vary
from about 20 to 100 feet and the superstructure was to be supported on piling
type foundations. This alternative was rejected by AES for the following
reasons:

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RAILROAD LOCATION

PLAN

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FIGURE 2-2

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o Potential inpact due to construction and future maintenance on
an intertidal wetland area located along the conveyor route;

o Public criticism - particularly concerned about potential

spills in the event of a breakdown or collision by water borne
craft and the impact on development potential of waterfront
properties, and

o Potential impact of low clearance on access to the Broward
River.

Coal handling systems remove coal from the coal delivery system, in
this case railcars, and convey it to a storage site. In addition, handling of
coal is necessary to take coal from the storage site to in-plant silos. Of
major concern is the control of fugitive dust and storage area runoff.

2.5 NO-ACTION ALTERNATIVE

Conventionally, the No-Action Alternative is the baseline for evaluating
the environmental impacts of the proposed project and the various structural
alternatives in the EIS process. It represents how existing conditions would
be altered in the future in the absence of federal action, in this case permit
approval. As is the case for developing alternative means of satisfying the
need for the project, the definition of the No-Action Alternative components
depends on the definition of need for the project. As presented in Section
1.5, the need for the project as defined for this SAR/EIS is additional
electricity-generating capacity and displacement of oil-fired generation from
1993 to 2025.

As defined, the No-Action scenario can be one in which no electrical
power generation plant is constructed and, therefore, the needs of the project
are not met or one in which the needs are met by an alternative power source
that would supply FP&L with 225 MW of electricity and displace the future
consumption of oil by 2.2 million barrels per year. The first scenario
involves a lowered reserve margin (below 15 percent) for Peninsular Florida's
electrical-generating capacity in 1993 and an increased future dependence on

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oil as a generating fuel. This scenario is considered to be the No-Action
Alternative for the EIS/SAR. The second scenario is addressed in a variety of
alternative means of satisfying the need of the project as presented in
Section 2.8.

2.6 POWER GENERATION ALTERNATIVES

Power generation alternatives as presented in this section are composed
of two components, fuel type and power production technology. Fuel type
alternatives are identified in Section 2.6.1. Oil is not considered a viable
fuel type alternative since the need for the project has been defined to
include the displacement of oil consumption (refer to Section 1.5).
Commercially-available technology alternatives are identified in Section

2.6.2.	It should be noted that some technology alternatives are presented as
a fuel type alternative because the fuel type and technology are not uniquely
separate components. The screening process used to develop a list of feasible
power generation alternatives for use in Florida is described in Section

2.6.3.	Fuel types and power production technologies that are not available
to Florida and/or are not commercially feasible were not considered for this
development of alternatives.

2.6.1 Fuel Types

These are alternatives to the use of coal and biomass/wood as proposed
for the CBCP. Fuel type alternatives exclude the use of oil and natural gas
(Refer to Section 1.5, need for the project). The coal for the proposed
project is to be crushed prior to combustion. Generally speaking, the
domestic coal supply is fairly stable with a market characterized by many
small companies with abundant reserves in all sulfur grades and excess
production capacity.

2.6.1.1 Nuclear

Nuclear fission produces energy when the heat released from a
controlled chain reaction of atom-splitting is used to boil water and
converted to electricity. Nuclear fission involves the splitting of heavy
atoms, usually uranium, and produces large amounts of energy.

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Nuclear power plants are currently in use throughout the United
States, and can produce anywhere from 100 to 1500 MW of electricity. The
thermal efficiency of the process averages about 32 percent. Current costs of
nuclear fuels per unit of power generated are lower than all fossil fuels and
are predicted to remain so.

Construction of nuclear powerplants has declined sharply in the
United States. The major handicaps to nuclear powerplants are rising con-
struction costs and construction time and public concern over powerplant
safety and radioactive-waste disposal.

The nuclear industry has been promoting the use of a "second
generation" of nuclear power plants that are supposed to be safer. Nuclear-
powered energy sources could replace the use of fossil fuels which add carbon
dioxide to the atmosphere and thereby contribute to the planet warming
phenomenon known as the "greenhouse effect".

The time required to build a nuclear powerplant has risen from four
years in 1970 to ten years today, after licensing. Since licensing takes
approximately four years, a power producer would have had to begin planning a
.new nuclear powerplant by 1979 in order to have it on line in 1993. Because
of this time requirement, the financial risk resulting from licensing
difficulties, the availability of an affordable small capacity plant and
"radioactivity" concerns for selling steam; nuclear power was not considered
to be a feasible alternative.

2.6.1.2. Municipal Solid Waste

With the drive to develop alternatives to solid waste landfills,
many agencies and municipalities are looking to utilize municipal solid waste
as a source of energy. The solid waste can be utilized as it is delivered
(Mass Burn Technology) or it can be processed to remove the recyclable and
noncombustible materials (Refuse Derived Fuel, RDF).

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Due to Che low Btu content of solid waste (=» 4500 Btu/pound),
typical energy recovery is only around 540 kwh/ton. This could eliminate
solid waste as a primary substitute for a coal fired plant due to tonage of
fuel required and the size of the plant required to provide 225 MW of
electricity. However, use of RDF technology could provide a supplemental fuel
to be burned in the CFB boilers along with the coal.

The use of a RDF supplement would impact material handling
capabilities, size of the boilers, reagent useage, and size of the pollution
control equipment. It would also require a source organization to provide the
RDF. The material handling would be impacted due to additional storage silos,
feed conveyors and injection requirment due to a second fuel. An impact would
also be felt in the size of the boilers. Additional heat transfer surface
would be necessitated along with an increase in size to handle the additional
volume of fuel. This is due to the lower heating value of the RDF as compared
to coal. The reagent requirements may go down, dependent upon the chemical
composition of the RDF. Typically, sulfur and chlorine levels would be
minimal due to the processing and overall acid gas levels would be reduced.
This would lower the amount of reagent required. Air pollution control
equipment would increase in size due to the higher volumes of air required in
the combustion process.

The overall impact to the project would be negative relative to the above
described reasons. Further consideration is not recommended based on the need
of the project as defined in this document.

2.6.1.3 Coal Gas

Low- or medium-Btu gas is produced from pulverized coal by heating
the coal in a pressurized chamber with steam with either air or pure oxygen.
The products of this reaction are, principally, carbon dioxide, carbon
monoxide, methane, and hydrogen. To produce gas with a higher Btu value
(synthetic natural gas), the medium-Btu gas must be upgraded.

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An average medium-Btu coal gasifier can produce from 7 to 10 billion
Btu per day, but multiple-user facilities exist which can produce upwards of
30 billion Btu's per day. Low-Btu gasifiers are currently used in a number of
industries in the United States to produce heat for industrial processes,
including brick ovens and lime kilns.

To use a coal gas as an alternative fuel for producing electricity,
it would have to be gasified, burned and converted to electricity in an
integrated electric power plant. In the first, or gasification stage, the
coal is partially reacted with a deficiency of oxygen to produce a low-heat-
ing-value fuel gas that can be readily cleaned. In the second stage, the
cleaned fuel gas is burned in a boiler that produces steam for a steam turbine
that generates the electric power. Some of the fuel gas can also be burned in
a combustion turbine as part of a combined-cycle unit as described in Section
2.6.2.4. Heat produced in the gasification stage is recovered by generating
steam. The gasifier steam is merged with the steam generated in the power
boiler. Such integration is necessary for high plant efficiency regardless of
whether the gasification system is retrofit to an existing power plant or
whether the system is applied to a new steam or combined-cycle power plant.

Coal gasification is considered a pre-combustion emission-control
process because sulfur and ash are removed in the gasification process which
produces a clean gas fuel for the boiler and/or combustion turbine. The
energy efficiency of the coal gasifier in an integrated system is about 96
percent.

2.6.1.4 Solar

Solar radiation can be converted directly into electrical energy
using photovoltaic cells, or it can be used to heat water which is then
vaporized to steam to power conventional turbines. These technologies are
described in Section 2.6.2. Solar power generation is technically feasible in
Florida. Florida has an insolation value (mean annual total direct and
diffuse radiation at the earth's surface) between 140 and 160 (kilogram-
calorie per square centimeter per year in a horizontal surface) which is
favorable for solar power generation.

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2.6.1.5 Wind

Wind energy systems convert the kinetic energy of wind into rotary,
translational, or oscillatory mechanical motion which can be converted to
electricity or heat. The output capacity from wind-powered electricity
generating units ranges from 500 KW to 4 MW with a thermal efficiency between
15 and 25 percent. Wind energy systems are technically feasible and com-
mercially viable.

Small wind energy systems for residential application are possible
but due to low wind speeds in Florida, they are not considered a viable energy
alternative for utility application. The U.S. Department of Energy (USDOE,
Office of Solar Energy Programs - Wind Systems Branch) estimates that the
average wind speed must be between 12 to 14 miles per hour to be considered a
valuable wind resource. The wind resource in Florida is minimal, as the
average wind speed is approximately 8.6 mph. The potential of wind as a
large-scale alternate energy source in Florida is among the lowest of the 48
contiguous states.

2.6.1.6 Hydroelectric

In hydroelectric power generation, the kinetic energy of falling
water is trapped and used to drive a turbine which generates electricity. The
water may be falling from a natural waterfall, or across a man-made dam built
for that purpose. In either case, there must be sufficient hydraulic head to
produce the energy of the falling water.

Hydroelectric powerplants are currently in extensive use across the
United States. Florida is quite flat, and few rivers have an adequate natural
head to generate significant amounts of energy. Therefore, the potential in
Florida is only for about 9 MW of electricity, with an energy efficiency of 66
to 80 percent.

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2.6.1.7 Ocean Tides

Tidal-electrical power is obtained from the oscillatory flow of
water in the filling and emptying of partially enclosed coastal basins during
the semidiurnal rise and fall of oceanic tides. The water flow while the
basin is filling or emptying can drive turbines propelling electric genera-
tors. Atlantic Ocean tides in Florida are only a few feet, which is far below
the practical level for tidal power application. Because there is not a
sufficient ocean tidal resource in Florida for large scale application, ocean-
tidal power will not be considered a viable energy alternative.

2.6.2 Technology Types

The following techniques are alternatives to the fluidized bed combustion
technology proposed for the CBCP. The CBCP is a concurrent-combustion
emission-control process in that sulfur is stripped and NOx formation is
controlled during the combustion process. These boilers produce steam to
drive an automatic extraction condensing turbine generator that produces
electricity and process steam.

2.6.2.1 Conventional Coal-Fired Steam Turbine

A conventional coal-fired electric power plant produces steam to
drive a high-speed turbine. It is considered a post-combustion emission-
control process because emissions are controlled after combustion, in as
removed from the boiler exhaust gases. Traditional emission-control processes
include dispersion (tall stacks) and lime/limestone scrubbers for SO2 removal
and mechanical cyclone collectors, scrubbers, electrostatic precipitators, and
baghouses for particulate removal. Processes and equipment for removing NOx
from the flue gas leaving a conventional coal-fired boiler are in develop-
mental stages. Boiler designs have been modified in some applications to
reduce oxide formation. Post-boiler gas treatment techniques currently being
used include catalytic decomposition, selective catalytic reduction (SCR),
selective noncatalytic reduction, and absorption.

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The design of the steam-producing combustion unit of a conventional
system must be suitable for optimum performance in burning the particular coal
available. Coals with high-fusion temperatures are inherently suitable for
burning, when pulverized, in dry-ash-removal hopper-bottom furnaces. Low
ash-fusion coals, in crushed form, are burned in the Cyclone Furnace with
slag-tap ash removal.

The conventional subcritical coal-fired unit selected for analysis
in the FCG studies burns pulverized coal in a conventional boiler designed to
produce high pressure steam. The steam is then expanded through a multi-
staged turbine which is directly coupled to an electrical generator which
produces energy for the utility grid.

Because of the complexity of the conventional coal-fired unit's
systems (including the emissions - control systems), they have long start-up
times and are not readily adaptable for cyclic operation. These units are
highly efficient and are capable of burning low-cost, widely available coal.

2.6.2.2 Combustion Turbine

Combustion turbines have been used by electric utilities and other
major industries for many years. Traditionally, utilities installed them for
peaking service, as their low capital costs, higher operating costs and
quick-start capabilities made them appropriate for low capacity factor
operation. Many combustion turbine installations utilize an axial flow
compressor which compresses outside air into a combustion area where fuel is
burned. The hot gases from the burning fuel-air mixture drive the turbine,
which in turn rotates a generator which produces electrical energy for the
utility grid. The hot exhaust gases from the turbine are then discharged into
the air.

Combustion turbines have the flexibility to burn natural gas,
distillate oil (No. 2 fuel oil), and in some cases residual oil which has been
treated to remove impurities. Additionally, gasified coal as described in
Section 2.6.2-. 2 could be burned if the economics of the fuel conversion are
justified. They have rapid start-up times compared to conventional fossil
steam generating units but are relatively inefficient compared to conventional
fossil steam or combined cycle units.

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2.6.2.3 Combined Cycle

A combined cycle plant is a hybrid of combustion turbines and a
steam driven turbine generator. The hot exhaust gases produced by the
combustion turbines that would otherwise be discharged into the air are passed
through a heat recovery steam generator which produces steam. This steam is
used to drive an additional turbine generator combination. This utilization
of the waste heat provides an overall plant efficiency that is much better
than that of a combustion turbine. The overall annual heat rate ranges from
7,300 to 7,500 Btu/kWh, which is more efficient than a base load coal unit.

Combined cycle plants have the same fuel flexibility available to a
combustion turbine: gas, distillate fuel, treated residual fuel and poten-
tially gasified coal. The capital investment is higher than that of a
combustion turbine, but is still substantially less than that of a conven-
tional coal-fired unit. Because of the modular configuration of combustion
turbines and heat recovery/steam turbines, combined cycle units may also be
operated as simple cycle combustion turbines, increasing dispatch flexibility
and yielding high unit availabilities.

2.6.2.4 Photovoltaic Cells

Photovoltaic cells convert solar radiation directly into electrical
energy. They have no moving parts and have been used for decades to power
satellites and other spaceships. Traditionally, the use of photovoltaic cells
as an alternative to a coal-powered electrical generating facility would
involve installation of photovoltaic cells in the homes of utility customers,
at the utility's expense. Customers would then pay a rental user fee. The
size of a photovoltaic cell can vary greatly, so that a cell could supply all
the electricity needs of a home. Recently, development has been looking at
the possibility of constructing central stations using the photovoltaic
technology. The commercial availability of centralized power generation,
though, is not expected to be available until 1996.

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Like all solar residential units, photovoltaic cells must have a
backup electrical system or an energy storage system (such as batteries) for
times when the sun does no.t provide sufficient energy. The costs of these
cells have dropped by about two orders of magnitude since the early 1970's,
which has made their use more attractive.

2.6.2.5 Passive Collection Panels

A centralized facility for solar power generation can be constructed
by assembling a number of passive collection panels at a specific site, and
using the total energy collected to heat water. The hot water is then
vaporized, and the resulting steam is used to power conventional turbines for
electricity generation. Central solar generators can produce up to 10 MW, but
higher production requires high capital costs, as well as a large geographic
area. Although the solar collection efficiency can be very high, the energy
efficiency of the system as a whole, (including collectors, storage facili-
ties, and generators) averages only about 20 percent. Solar power generation
is feasible in Florida with an expected capacity factor of 60 percent but the
negative impact of committing large areas of land makes this technology an
improbable alternative.

An alternative to a centralized facility is the installation of
individual residential solar water heating systems with small (approximately
40 square feet) collection panels. These systems can be expected to replace
the use of approximately 2,100 kwh of electricity per year. Also they require
a backup system for times when the weather rendered them ineffective.

2.7 MANAGEMENT ALTERNATIVES

2.7.1 Purchase of Power

As used in this EIS/SAR, the management alternative of purchasing power
is having FP&L purchase power from an existing power plant not owned by FP&L
to replace the 225 MW needed capacity that the CBCP was expected to fulfill.
The proposed project is by definition a purchased-power alternative in itself,
but is different in that it requires construction of a new plant. The

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identification of feasible power suppliers that could be contracted by FP&L
are provided in Section 2.8 along with a description of any additional trans-
mission capacity needs.

The alternative of purchasing power is valid only if there is trans-
mission capability available. The Florida transmission systems are part of
SERC and the overall electric power systems of the eastern United States. The
peninsular Florida systems can exchange assistance with the Southern Company
(SOU) and the Tennessee Valley Authority (TVA) through several transmission
interconnections.

Purchasing power from power generators offer some advantages to a utility
such as FP&L including reduction of generation investment, diversification of
investment base, and becoming a selling service. Possible risks to FP&L in
such an arrangement include paying too much for power, reduction of system
reliability, investment in interconnections yielding insufficient payback, and
the need for self-service/retail sales wheeling.

2.7.2 Joint Projects

Joint ownership of a project is an arrangement normally undertaken to
diversify risk and, in some cases, to take advantage of the tax and financial
market changes that may occur.

For the proposed CBCP the entities involved include AES-CB (the appli-
cant, a wholly owned subsidiary of Applied Energy Services, Inc., a privately
held corporation), SK (privately held corporation which owns and operates the
paper mill that is to receive the CBCP's process steam), JEA (a municipally
owned electric utility that is to wheel the 225 MW of generated electricity),
and FP&L (an investor owned utility that is to buy the 225 MW electricity to
fulfill its future capacity needs). Joint ownership of the CBCP or any of the
proposed alternative means presented in Section 2.8 could be undertaken
between any combination of the involved entities.

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2.7.3 Conservation

Conservation as a management alternative includes conservation practices
for reducing the demand of the product and for increasing the efficiency in
supplying the product. The product being, in this case, electrical energy.
The legislative intent of FEECA to reduce "the growth rates of electric con-
sumption 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. Both conservation approaches are
addressed below.

2.7.3.1 Demand-Side Conservation Practices

The forecasting of long-term energy sales and peak demands is
generally based on historical data. The models used for such forecasting can
contain several variables to reflect changes in consumption (demand) due to
variations in measurable parameters. In terms of electrical energy, FP&L has
defined the following parameters as part of their load forecasting in their
"Ten Year Power Plant Site Plan, 1989-1998".

o Price term - reflects changes in consumption due to changing
prices of produced electricity;

o Weather term - reflects changes in consumption due to variation
in the weather (accounts for minimum and maximum temperatures);

o Per capita income - reflects changes in consumption due to
changes in the service area's economic prosperity; and

o Appliance term - reflects changes in consumption due to

improved appliance efficiencies and/or increase appliance use.

In the plan, FP&L stated that demand forecast models cannot predict
the effects of future technological advancements or changes in consumer
lifestyle. In order to account for these anticipated changes in their load
projections, FP&L has evaluated their seven (7) conservation programs and

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estimated the cumulative effects of these programs on the peak demand fore-
casts. These programs, which are listed in Table 2-2, are generally imple-
mented by encouraging monetary savings for the consumer. No legislation
exists for enforcing demand side conservation. Subsequently, quantifying the
effects of such programs for forecasting purposes is difficult and incurs the
risk of understating future demands.

2.7.3.2 Supply-Side Conservation Practices

Pursuant to FEECA, Section 366.82 F.S., enacted by the 1980 Legi-
slature, the FPSC has the responsibility to establish conservation goals for
the electric utilities of Florida. In QF need determination cases prior to
the CBCP hearing, the FPSC has concluded that "cogeneration is a conservation
measure". Since then the FPSC has rethought this position. In the FPSC Order
No. 21491 it is stated that there is a recognition in the industry that
cogeneration 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 a
cogeneration unit could be lower than that of comparable noncogeneration units
simply because the sales price of the steam produced by the QF and sold to the
steam host is high and produces a great deal of profit.

2.8 ALTERNATIVE MEANS OF SATISFYING THE NEED FOR THE PROJECT

2.8.1 Need for Analysis of Alternatives

As stated in Section 1.5, the determination of need for the CBCP is based
on the need for additional electricity generating capacity and for the
displacement of future oil and gas 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 225 MW of electric power to FP&L and to displace 2.2
million barrels per year of future oil consumption or gas equivalent. The
FPSC did not consider any alternatives to fulfill these requirements during

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Table 2-2

Long-Term Forecast
Conservation Programs
FP&L, "Ten Year Power Plant Site Plan 1989-1998"

1.	Commercial/Industrial Lighting Incentive Program

This is an incentive program which began in mid-1984 to encourage demand
and non-demand commercial/industrial customers to replace their fluor-
escent lamps with reduced wattage energy efficient lamps.

2.	Residential Pool Usage Moderation Program (Pool Pump Timer)

The Residential Pool Pump Program was developed by FPL for the purpose of
lowering both the annual energy usage (KWH) and peak. demand requirements
(KW) of residential customers who own swimming pools.

FPL began offering pool audits to its residential customers in June,
1981. The auditors place timing devices on swimming pool pumps. The
timers shut off the pool pumps during the time of the day when the system
normally experiences its peak demand; furthermore, they reduce the number
of hours of daily operation of most swimming pool pumps, while still
maintaining pool cleanliness.

3.	Commercial/Industrial Customer Audit Program

This is an energy audit program designed to assist commercial/industrial
customers in making their facilities more energy efficient through the
installation of conservation measures and the implementation of con-
servation practices.

Each year, FPL offers energy audits to small (peak demand of 20 KW or
less), medium (21 through 499 KW peak demand) and large (peak demand of
500 KW or more) commercial/industrial customers. The savings for each
customers are commensurate with its size.

Residential Customer Incentive Programs

In an effort to induce customers to upgrade the thermal efficiency of
their dwellings and/or to purchase more energy efficient appliances, FPL
has initiated incentive programs in each of the following areas:

4.	Home energy loss prevention.

5.	Window film treatment.

6.	Water heating.

7.	Residential ceiling insulation.

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their evaluation of need for this project. The FPSC stated that the CBCP was
a qualifying facility pursuant to the PURPA regulations and therefore was the
most cost-effective alternative. Subsequently, the FCG 1989 Generation
Expansion Planning Studies document was used as the basis for alternative
development for this SAR/EIS.

The environmental evaluation of alternatives to the CBCP was identified
at the public scoping meeting as a major issue for consideration in the
SAR/EIS. In addition, USEPA is required by the regulations of NEPA to
identify and assess reasonable alternatives to the proposed action that could
potentially avoid or minimize adverse effects on the quality of the human
environment.

The purpose of EIS alternatives analysis is to consider feasible
alternatives that would meet the CBCP objectives of supplying electricity and
displacing gas and/or oil consumption with a less expensive supply of
electricity for the FP&L customers. The economic and environmental
ramifications of these alternatives were examined.

2.8.2 Available Technologies for Oil and Gas Displacement

In order to develop alternatives, the technologies appropriate for use in
Florida during the current time frame had to be identified. These
technologies must meet the following criteria:

o Technology must be implementable by 1996;

o Technology must be technically and commercially proven;

o Technology should displace the use of oiland/or gas as a fuel
source; and

o Needed fuel resource must be available in Florida or a

transportation network must be feasible to bring in the fuel.

Many alternative technologies can be removed from further consideration
based on extensive lead time requirements, regulatory and/or environmental
constraints, high operation and/or construction costs, or the unproven nature
of the technology. Those technologies which were considered as viable

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alternatives to the CBCP were not restricted by regulatory, environmental, or
technological constraints; were relatively cost-effective; and could be
brought on-line within the required time frame.

In summary, the technologies which met the criteria and were identified
as feasible technologies for alternatives to the CBCP included the following:

o purchase of power;

o reduction in electrical demand by installing residential solar hot
water heaters;

o construction of a combustion turbine power plant (gasified
coal- fueled);

o construction of a combined cycle power plant (gasified coal-fueled);
and

o construction of a conventional coal-fired power plant.

2.8.3 Development of Alternatives

In view of the fact that the FPSC did not analyze alternative
technologies for the preparation of their final order (refer to Section 1.5 of
this document) and that the planning studies conducted by the FP&L and by the
FCG only provided general data for the alternative power systems analyzed, the
alternatives developed for this document could not be developed to the level
of detail provided by AES-CB for the proposed project. However, the
alternatives presented have been developed to a level of detail sufficient to
determine the basic engineering and economic factors required to make a
meaningful comparison of their relative environmental impacts.

2.8.3.1 Criteria for Alternative Development

The feasible technologies were combined into alternatives which met
the following criteria:

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

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

o the alternative must be implementable by 1996.

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Large-scale technologies such as construction of a combustion
turbine power plant were proposed for the CBCP site. In this way, the
environmental impacts of the alternative could be evaluated for a particular
site. Small-scale technologies (i.e., installation of residential solar hot
water heaters) could not reasonably be tied to a particular site or even a
particular area within the service area of the utility because their
application would be so widely dispersed. Therefore, assessment of the
alternatives involving a small-scale alternative was treated generally.

Table 2-3 summarizes the alternative's advantages and disadvantages
in satisfying the need of the project.

2.8.3.2 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 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 was entitled the Cost Effective
Oil Backout Study. 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 was produced through
the cooperative efforts of representatives of FCG, SOU, TVA and FPSC staff.

Two incremental 500 MW blocks of energy transfers above the existing
3,200 MW transfer limit were analyzed. Savings in the study were identified
in two areas: energy savings and transmission loss savings. The energy
savings were calculated by detailed comparison of the incremental costs of
increased generation in either Southern or TVA systems in order to offset
oil-fired generation in Florida. Transmission loss savings were calculated by
analyzing the potential increase in efficiency of the transmission system
through the addition of the new transmission facilities. The energy savings
and transmission loss savings were compared with the incremental costs
associated with the transmission facilities required to accomplish the
additional transfers to Florida. As with the energy and transmission loss
savings, the cost of incremental transmission facilities was studied and
amortized over the 1988-1995 period.

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Table 2-3
Power Supply Alternatives
Summary of Advantages and Disadvantages

Alternatives

Advantages

Disadvantages

1. Purchase of Power

o No significant environ-
mental impact on the
Jacksonville area

o Low reliability impact
o High costs of
transmission

Residential Solar o Low to no significant	o Needs 100% backup

Water Heaters	environmental impact	system for inclement

weather conditions
o Coordination of

implementation efforts
complex
o Responsibilities for
maintenance need to be
clearly defined
o Questionnable
reliability

3. Combustion Turbine o
Power Plant
(gasified coal o
fueled)

Coal based substitute
for Natural Gas
Has ability to meet air
emissions restrictions

Highly complex
refining process that
must be implemented
with power producing
equipment

Just starting to come
out of demonstration
stage to commercial
viability

May have some problems
with CO2 emissions
High maintenance
operation

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Table 2-3
Power Supply Alternatives
Summary of Advantages and Disadvantages
(Continued)

Alternatives	Advantages	Disadvantages

4. Combined Cycle o
Plant (gasified
coal-fueled)	o

equipment
o Just starting to come
out of demonstration
stage to commercial
viability
o May have some problems

with CC>2 emissions
o High maintenance
operation

Coal based substitute

for Natural Gas
Has ability to meet air
emissions restrictions

o Highly complex

refining process that
must be implemented
with power producing

5. Conventional
Coal- fired
Power Plant

o Known and well-tested

Technology
o Plentiful fuel source

o Major environmental
impact on air quality
which requires
expensive pollution
control facilities

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The study showed 500 MW and 1,000 MW of additional sales above the
3,200 MW limit would not be economical. In all cases, the increased costs of
the incremental transmission facilities exceeded the savings from energy and
reduced transmission losses.

One of the major driving forces in the economics of the
cost-effective oil backout study was the assumed difference between the price
of coal and the price of oil during the 1988-1995 study period. If the
assumed coal/oil differential had been higher, the energy savings associated
with the additional transfers would have been higher. Conversely, lower
coal/oil differentials would have caused the energy savings associated with
the transfers to be lower.

The FCG current high-band fuel forecast shows coal/oil differentials
that are lower than those assumed at the time of the 1985 Cost Effective Oil
Backout Study. This leads to the conclusion that it is unlikely that
additional transfers from either SOU or TVA above the existing 3,200 MW
transfer capability would be economical given the current fuel price outlook.
In addition to the economic analysis of increased transfer capability, a
sensitivity analysis which analyzed the reliability impact of additional
transfer capbility was conducted. This sensitivity showed minimal reliability
benefit from an increase in transfer capability.

2.8.3.3 Alternative 2 - Residential Solar Hot Water Heaters

Under this alternative, it is assumed for alternative develoment and
evalution purposes that FP&L would sponsor a retrofitting of solar water
heaters for 50% of all new and 10% of all existing customers in its service
areas. In case of a retrofit unit, the utility is assumed to pay for the
manufacture and installation of the flat-plate collector, the additional
piping, the pump, and the storage tank. New units would be very similar,
although the additional storage tank is not absolutely necessary. Alternative
financing not addressed here could include purchases of the heaters directly
by the customer with the provision of no-interest loans and/or the
distribution of costs between the utility and the customers (say 50%-50% cost
distribution).

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By 1998, this program would result in the installation of
approximately 729,600 solar water heating units in the FP&L service area. The
construction of the solar units is assumed to occur evenly throughout a
nine-year period (1990-1998) and would require FP&L to provide about 81,000
units/year. Each solar water heater unit is expected to replace the use of
approximately 2,100 kwh of electricity per year at the end of the installation
period. This replacement would save FP&L 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, and
solid wastes. In addition, they would require no increase in groundwater
consumption. The implemention of the solar water heater program can 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 in case weather conditions render them ineffective for an extended
period of time. These backup systems would have to provide peak capacity
sufficient to meet demand. Table 2-3 lists the assumption and calculations
used for the development of this alternative.

2.8.3.4 Alternative 3 - Construction of a Combustion Turbine Power
Plant with Coal Gasification

FP&L or the applicant would build a combustion turbine power plant
with a capacity of 225 MW at the proposed site. The facility would be
comprised of three 75 MW (net) gas turbine generators with Heat Recovery Steam
Generators (HRSG). Fuel for the facility would be generated in a fully
integrated coal gasification system. Projected lead time for this facility is
four to five years.

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 off gas generated is then scrubbed of particulates and
ammonia and then the suflur is removed. Dependent upon the process, the
sulfur may be recovered and sold. This process provides a relatively
"environmentally clean" fuel for the gas turbine. This "coal gas" can be
subsitute fuel for natural gas.

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Table 2-4
Solar Water Heating Units
Assumptions and Calculations

Estimated Number of FP&L Customers
for 1990 (1)

Assume 50% live in single family
units and 20% of these "existing"
homes will be retrofitted with a
solar hot water system

Estimated Number of FP&L Customers
for 1998 (1)

Assume 50% of these customers will
be fitted with solar hot water
systems

Total number of units (homes)

Assume a solar hot water system
that has an average collector size
of 40 sq. ft. will replace 2,100
kwh/year/home

Assume heat rate of backed out oil
units = 10 MBtu/Mwh

Assume heating value of oil = 0.151
MBtu/gal

Assume barrel size = 42 gal

3,194,466 customers

x. 50
x. 20

319,447 Existing customers to
receive systems

4,014,689
3.194.466
820,223
x. 50

Total projected

customers
Existing estimated

customers
New Customers

410,112 Future customers

to receive systems

729,559 (319,447 + 410,112)

Assume 81,062 units built/year
(729,559/9)

Assume 42.3 person hours to be invested
per system for design, manufacture,
installation, and maintenance.

Assume 2080 work hours/year/
person

x 2.1 Mwh/year/horae
x 10 MBtu/Mwh

/ .151 MBtu/gal

	/ 42 gal/barrel	

2,415,758 barrels of oil (2.4

Mbarrels)

81,062 units

x 42.3 person hours/system

% 2.080 hours/year/person
1,649 employees required

Source: FP&L's Ten Year Power Plant Site Plan, 1989

1998

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The gasification process is essentially a minature petrochemical
refinery. It effectively breaks down the coal into its basic elements by use
of heat and pressure. These basic elements are oxidized in a combustor. The
gas that is generated is low in Btu value and has a mixture of H2 , CO, and
methane along with CO2 , N2, and H2O. Exact composition can have a tremendous
effect of the sizing of the combustion turbine.

The installation of a combustion turbine system would not be
economically feasible if it was only there to generate electricity. The only
way this system can be justified is if the low pressure steam, downstream of
the HRSG is utilized in a process.

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

FP&L or the applicant would build a combined cycle coal gasification
power facility with a capacity of 230 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 consist of two gas turbines with
associated heat recovery steam generators (HRSG) and one steam turbine. The
estimated project lead time is 4 years. The condenser cooling system would
require a freshwater source to cool through evaporation and heat transfer.
Plant stack emissions would primarily be SO2 and NO2.

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). The phase
construction can begin with the construction of the combustion turbines
followed by the steam cycle and then the gasifier.

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

FP&L 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 be comprised of a single pulverized coal, high pressure boiler
with a steam turbine generator set. Current design practices relative to NOx
control would need to be incorporated in the boiler and burner designs.
Additional NOx control, downstream of the combustion zone, may be required in
the form of catatytic decompostion, selective catalytic reduction, selective
noncatalytic reduction and absorption. These four methods have little history
from which to develop any probabilities of meeting present and/or future NOx
requirements.

These units are highly efficient and are capable of burning low-cost
widely available coal. However, due to inherent design requirements of the
emission controls, the coal specification must be developed during design and
utilized during operation. The emission control systems design are based on
coal specification and a deviation in the suflur or ash content, as examples,
could have an adverse impact on the ability of the system to meet environ-
mental requirements. This may limit the sources for long term coal supplies.
The coal would typically be delivered to the site by unit train or barge.

A conventional coal fired plant is typically designed for base load
operation. Due to extended start-up sequences and typically poor turndown
ratios, pulverized coal (PC) and cyclonic type boilers are ill suited for
cyclic or peaking operations. Normally, the most cost effective and
environmentally sound method of operation is to start these units up and run
them at maximum load year round. The only downtime should be for planned
outages.

Due to the size, and complexity of a coal fired plant of this type
it is estimated that project lead time is 5-8 years. This could be
implemented within the required in-service date of 1996.

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2.8.4 Economic Analysis of the Alternatives Including
the Proposed Project

The basis of an economic analysis in the evaluation of the alternatives
should be an analysis of the impact on the customer. The FCG in their
studies, measures this impact by the cummulative present worth of future
revenue requirements. In addition, the FCG evaluates alternatives by
considering "strategic issues" including the following:

o	Capital investment and financial risk;

o	Construction flexibility;

o	Potential changes in governmental regulations;

o	Statewide fuel diversity;

o	Unit fuel flexibility; and

o	Project lead time.

Since the alternatives developed for this study were not developed to the
detailed needed to do an in depth economic analyses as described in FCG
studies, the issues presented above could not be addressed in detail. The
economic analyses of this section is a simple economic screening that compares
the present worth values of the power supply alternatives for each KW of power
produced. Table 2-5 summarizes the economic analysis of the selected
alternatives.

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Table 2-5
Power Supply Alternatives
Summary of Economic Analysis (1)

Estimated Construction/
Alternatives Installation Costs

Estimated Annual (2)
O&M Costs

Present (3)
Worth Value

1. Purchase of Power

(Not available)

(Not available)

(Not available)

2. Residential Solar
Water Heaters

$1,760/KW (4)

$ 8/KW/year

1,843/KW

3. Combustion Turbine
Power Plant
(gasified coal-fueled)

$1,260/KW (5)

$16/KW/year

1,426/KW

4. Combined Cycle Power
Plant (gasified coal-
fueled)

$1,400/KW

$20/KW/year

1,608/KW

5. Conventional Coal-
fired Power Plant

$1,500/KW

$14/KW/year

1,645/KW

CBCP

$1,450

$18/KW/year

1,637/KW

(1)	Cost estimates in first quarter, 1990 Dollars.

(2)	Assumes a 87% capacity factor for Alternatives 3, 4, 5 and CBCP.

(3)	Assumes an 8.875 percent compound interest rate for a 30 year period.

(4)	This estimate includes a backup system ($353/KW natural-fired combustion turbine
facility).

(5)	This estimate assumes an open cycle facility that requires an additional steam
turbine for the gasification plant.

NOTE: The cost estimates, unlike "levelized" cost estimates, do not include fuel costs
and do not address a range of unit capacity factors .

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CHAPTER 3

AFFECTED ENVIRONMENT

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3.0 AFFECTED ENVIRONMENT

This chapter describes the existing environment at those locations which
could potentially be affected by the proposed project or other alternatives
under evaluation. Because the project involves modifications at an existing
papermill and because of the cogeneration aspects of the project, certain
alternatives are not available.

3.1 AIR RESOURCES

This section provides a summary of the existing air resources at the
proposed plant site. Detailed information concerning air resources is
presented in Appendix L.

3.1.1 Climatological/Dispersion Characteristics

The terrain surrounding the CBCP site is level. Easterly maritime winds
blow about 40% of the time which produces a moderate climate. Summers are
long, warm and relatively humid. Winters are mild, but occasionally
interrupted by invasions of cool to occasionally cold air from the north. The
following summary of existing climatological conditions in the Jacksonville
area is based on past weather data.

The annual mean temperature at Jacksonville is 68.4°F. June, July, and
August are the hottest months, with temperatures averaging near 80°F.

December, January, and February are the coolest months with mean temperatures
near 55° F. In winter, temperatures fall to freezing or below about 12 times
per year. Annual rainfall averages about 54 to 55 inches per year. Rainfall
averages over seven inches per month during the summer. Infrequently, heavy
rains associated with tropical storms can deposit several inches of rain in a
short period of time. The driest months are November, December, and January
when precipitation averages less than three inches per month. The highest
annual average 10-year, 24-hour rainfall event is about 7.5 inches. The
100-year, 24-hour rainfall event is about 11 inches.

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The average relative humidity is about 75%. In the early morning
relative humidities average about 90% while afternoon humidities average 55%.
Daily sunshine in December averages 5.5 hours; in May the average daily

sunshine is 9.0 hours.

Prevailing winds are northeasterly in the autumn and early winter
shifting to northwesterly in late winter and early spring. In spring and
summer winds move to the southwest then to the southeast as sea breezes exert
their influences. Wind speeds average slightly less than nine mph overall.
Wind speed are slightly higher during spring than in other seasons. The mean
annual morning mixing height at Jacksonville is 1,600 feet. Afternoon mixing
heights average about 4,600 feet annually.

3.1.2 Air Quality

The area of Jacksonville bounded by the St. Johns River to the east
and south, Trout River on the north and 1-95 on the west is a designated
non-attainment area for TSP. Violations of both the annual standard (60
ug/m3) and the 24-hour standard (150 ug/ra3) are indicated. Average annual TSP
values of less than 40 ug/m3 and average 24-hour values of less than 90 ug/m3
are indicative of the outlying areas of Jacksonville.

Annual values of SO2 in outlying areas of Jacksonville are 5 to 15
ug/m3. Annual values in areas close to major sources have been reported to be
in the range of 20 ug/m3. Highest 24-hour values in outlying areas are
primarily in the range of 30 to 60 ug/m3, whereas monitors close to the major
emissions sources have recorded highest 24-hour averages of 100 to 200 ug/m3
and highest 1-hour averages of 400 to 900 ug/m3. Most of the monitors are
significantly influenced by the existing major sources of SO2. While
Jacksonville is considered attainment for SO2, recent modelling submitted with
consideration of downwash have indicated potential violations of air quality
standards in certain of the industrial areas.

Annual NO2 concentrations in outlying areas average less than 20
ug/m3, whereas downtown values are about 40 ug/m3. Some monitors are affected
by major point sources and others are presumably influenced by transportation

3-2

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sources. These values are well below the standard of 100 ug/m3. Maximum CO
levels are about 8000 ug/m3 (8-hour average) and 14,000 ug/m3 (1-hour
average). These levels are well below the allowable standard of 10,000 ug/m3
(8-hour average) and 40,000 ug/m3 (1-hour average). The 1-hour average State
standard for ozone of 160 ug/m3 is often exceeded in the warm summer months;
however, maximum values reported have been nearly 300 ug/m3. The entire
Jacksonville area is designated non-attainment of the NAAQS for ozone.

Sulfates are associated with acidic precipitation and therefore have
received more attention in recent years even though there are no ambient
sulfate standards. In 1979 FDER determined that concentrations of sulfate had
a mean of 9.06 ug/m3 with a range of 2.90 ug/m3 to 18.20 ug/m3. Acid rain
measurements in the Jacksonville area during 1978 to 1979 indicated a volume
weighted pH of 4.74.

3.1.3	Existing Air Pollution Sources

The locations of major air pollution sources in the area is depicted in
Figure 3-1. In addition to these major sources, there are a large number of
minor sources in the area which also contribute to air pollution. The FDER is
working with a number of the existing sources to resolve the modeled SO2
violations.

3.1.4	Regulatory Framework

This section summarizes the Federal and State regulatory requirements for
air emissions that the CBCP must meet. Also included is a summary of air
emission regulations which would have to be met for alternatives.

3.1.4.1 Federal Regulatory Requirements

CBCP will have to meet two major Federal requirements: National
Ambient Air Quality Standards (NAAQS) and Prevention of Significant
Deterioration (PSD). The NAAQS establishes a limit for air quality
degradation in areas of the United States. The PSD program limits the amounts
of increase (increment) over a baseline level above which a new source may not
deteriorate air quality.

3-3

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JACKSONVILLE
INTERNATIONAL
AISPORT

• SHE77IELD (?)

/

T (S,N)

• r-'i asjRpp

SK PAPER MILI_

;ea no?.--:sidi



B MAJOR EMISSION SOURCE

• MONITORING SITE
P - PARTICULATES
S ¦ SULFUR DIOXIDE
N - NITHOCEN DIOXIDE
'///, TSP NONATTAINMENT AREA

Locations of major emission sources and monitoring sites in
the Jacksonville area (TEA/FP&L 1981a).	FIGURE 3-

3-4

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The 1970 Clean Air Act Amendments (CAAA) required the Federal
Government to set standards for ambient air quality for the principal type
pollutants (criteria pollutants) and the levels of each that should not be
exceeded for the protection of public health and welfare (Table 3-1). In
areas where the air quality does not meet these standards (non-attainment),
new pollution sources are restricted through the requirements of pollution
offsets. Prior to the construction of a new significant contributor of the
non-attainment pollutant in or near a non-attainment area, an equal or greater
reduction of that pollutant from another pollution source in the area must be
secured. This generally precludes the development of major industries in a
non-attainment area due to the expense of obtaining the required emissions
offset.

In areas with air quality cleaner than the NAAQS, PSD applies. PSD
restricts the amount of air quality degradation in an area to a specific
amount (increment). PSD applies to sulfur dioxide (SO2), particulates (TSP),
and nitrogen oxides (NOx). The amount of incremental increase depends on the
classification of the area affected (Table 3-2). In Class I areas, which are
predominately large national parks, the increment is very small. A moderate
increment is allowed in Class II areas, while the greatest increments are
allowed in Class III areas. Presently there are no Class III areas in
Florida.

Two additional Federal regulations associated with PSD include the
New Source Performance Standards (NSPS) and Best Available Control Technology
(BACT). Fossil fuel-fired steam generating units of more than 250 MMBtu/hr of
heat input produce three types of emissions for which USEPA has established
NSPS (44 CFR (113) 3357933624, June 11, 1979). The applicable NSPS for these
pollutants from coal-fired units are as follows:

o Particulate Matter - 0.03 lb/MMBtu heat input and 20%

opacity based on a six minute
average.

3-5

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Table 3-1

FEDERAL AND FLORIDA AMBIENT AIR QUALITY STANDARDS

Pollutant

Sampling
Period

Federal Standards

Primary
ug/m^

Secondary
ug/m?

Florida
Standards
ug/m^

Sulfur Dioxide (SO2)

Annual

24-hour

3-hour

80
365

1,300

60
260
1,300

Nitrogen Dioxide (NOj)
Particulate Matter (PM^q)

Annual

Annual
24-hour

100

50
150

100

50
150

100

50
150

Carbon Monoxide* (CO)

8-hour
1-hour

10
40

10
40

Ozone (O3)

1-hour

235

235

235

Lead (Pb)

Calendar
Quarter

1.5

1.5

1.5

* Units are mg/m'.

3-6

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Table 3-2

PSD CLASS I AND CLASS II AIR QUALITY INCREMENTS

Pollutant Class I Increment	Class II Increment
S02

Annual	2	20

24-hour	5	(2) 91 (2)

3-hour	25	(2) 512 (2)

Particulates

Annual	5	19

24-hour	10	37

NOx (1)

Annual	2.5	25

(1)	Proposed February 8, 1988.

(2)	Increments that are not to be exceeded more than once per year.

3-7

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o Sulfur Dioxide	- 1.2 lb/MMBtu heat input and a 90%

reduction in potential SO2 emissions
is required at all times except when
atmospheric emissions are less than
0.60 lb/MMBtu per hour heat input.

When SO2 emissions are less than 0.60
lb/MMBtu heat input, a 70% reduction
in potential emissions is required.

Compliance with the emission limit
and percent reduction requirements is
determined by continuous monitoring
to obtain a 30-day rolling average.

o Nitrogen Oxides - 0.6 lb/MMBtu heat input for bitumin-
ous coal and a 65% reduction in
potential NOx emissions based on a
30-day rolling average expressed as
NO2. The percent reduction is not
controlling as USEPA has determined
that compliance with the emission
limitation will assure compliance
with the percent reduction require-
ment .

In addition to these requirements, the Clean Air Act (CAA) as
amended in 1977 and the implementing PSD regulations require a case-by-case
evaluation of BACT for projects the size of the CBCP. BACT is defined as
follows in the Federal regulations:

"Best available control technology means an emission
limitation (including a viable emission standard) based on
the maximum degree of reduction for each pollutant subject
to regulation under the Act which would be emitted from any
proposed major stationary source or major modification, which
the Administrator, on a case-by-case basis, taking into
account energy, environmental, and economic impacts and other

3-8

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costs determines is achievable for such source or modifica-
tion through application of production processes or available
methods, systems, and techniques, including fuel cleaning or
treatment or innovative fuel combustion techniques, for
control of such pollutant. In no event shall application
of best available control technology result in emissions of
any pollutant which would exceed the emissions allowed by any
applicable standard under 40 CFR Part 60 and Part 61."

3.1.4.2 State Regulatory Requirements

The Florida rules and regulations pertaining to air quality are
similar to the Federal regulations. The Florida Air Quality Regulations are
defined in FAC 17-2, and administered by the FDER (Table 3-1). The primary
difference between the Federal requirements and Florida's requirements is in
the NSPS. Florida's NSPS are as follows:

o Particulate Matter 0.1 lb/MMBtu, two hour average and

20% opacity.

o Sulfur Dioxide

1.2 lb/MMBtu, maximum two-hour
average, no percent reduction
requirement.

o Nitrogen Oxides

0.7 lb/MMBtu, maximum two-hour
average.

3.2 SURFACE WATER RESOURCES

This section describes the existing surface water resources which may be
affected by the CBCP. The waters of concern include the St. Johns River and
the Broward River. CBCP will discharge to the existing SK paper mill
discharge pipeline to the St. Johns River. The Broward River serves as the
western boundary of the proposed site. These rivers have been classified by
the State of Florida as Class III marine waters - "Recreation, Propagation and
Maintenance of a Healthy, Weil-Balanced Population of Fish and Wildlife", (FAC
17-3.161). Applicable criteria and conditions for toxic substances are

3-9

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provided in FAC 17-3 and 17.4; and particularly Sections 17-3.051, 17-3.121,
and 17-4.244. "All surface waters of the State shall at all times be free
from domestic, industrial, agricultural, or other man-induced non-thermal
components of discharges which, alone or in combination with other substances
or in combination with other components of discharges (whether thermal or
non-thermal): are acutely toxic [FAC 17-3.051(1)(d)]." "Acute Toxicity" is
defined in FAC 17-3.3.021(1) as: "the presence of one or more substances or
characteristics or components of substances in amounts which: (a) Are greater
than one-third (1/3) of the amount lethal to 50% of the test organisms in 96
hours (96 hr. LC50) where the 96 hr. LC50 is the lowest value which has been
determined for a species significant to the indigenous aquatic community; or
(b) may reasonably be expected, based upon evaluation by generally accepted
scientific methods, to produce effects equal to those of the concentration of
the substance specified in (a) above." FAC 17-4.244(4) provides "... in no
event shall the maximum concentration of wastes in the mixing zone exceed the
amount lethal to 50% of the test organisms in 96 hours (96 hr. LC50) for a
species significant to the indigenous aquatic community." Additionally, at the
edge of an assigned mixing zone, specific criteria are applicable (FAC
17-3.121). For instance, the criterion for total copper is 0.015 mg/1 at the
edge of the mixing zone [FAC 17-3.121(11)]. Florida statutes allow variances
from water quality criteria if ambient levels of constituents in State waters
exceed the specified water quality standards presented in Table 3-3 (FAC
17-3.031). AES-CB has applied for a variance for the discharge of iron from
the CBCP.

3.2.1 St. Johns River at Jacksonville

At the CBCP site, the St. Johns River runs in an east-west direction
lying south of the site. The SK paper mill discharge pipeline extends into
the river to a point near the main shipping channel. The river in the
vicinity of CBCP is greatly influenced by the Atlantic Ocean. Due to the
tidal influence, currents are highly varied and the flow in the St. Johns
River may change direction up to four times per day. The estimated freshwater
flow in the St. Johns River is approximately 9300 cfs. In 1979-1980 flow
measurements were made in the river approximately three miles east of the

3-10

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Table 3-3
WATER QUALITY CRITERIA

Parameter

Oil and Grease

Dissolved or
Emulsified

Undissolved

Class II

5.0 mg/1

No visible oil to
interfere with
beneficial use

Class III
Fresh
Chloride
Concentrate
<1.500 mg/1

5.0 mg/1

No visible oil to
interfere with
beneficial use

Class III
Marine
Chloride
Concentrate
>1,500 mg/1

5.0 mg/1

No visible oil to
interfere with
beneficial use

Pesticides and
Herbicides

Aldrin Plus

Dieldrin
Chlordane
DDT

Demeton

Endosulfan

Endrin

Guthion

Heptachlor

Lindane

Malathion

Methoxychlor

Mirex

Parathion

Toxaphene

pH Range

0.003 ug/1
0.004 ug/1
0.001 ug/1
0.1 ug/1

0.001 ug/1
0.004 ug/1
0.01 ug/1
0.001 ug/1
0.004 ug/1

0.1 ug/1
0.03 ug/1
0.001 ug/1
0.04 ug/1
0.005 ug/1

6.5 to 8.5

pH Variation from
Background	+ 1.0

Phenolic Compounds 1.0 ug/1

0.1 ug/1

0.003 ug/1

0.01 ug/1
0.001 ug/1

o.l Ug/1

0.003 ug/1
0.004 ug/1
0.01 ug/1
0.001 ug/1
0.01 ug/1

0.1 ug/1
0.03 ug/1
0.001 ug/1
0.04 ug/1
0.005 ug/1

6.0 to 8.5

± i.o

1.0 ug/1

Phosophorous
(Elemental)

0.003 ug/1
0.004 ug/1
0.001 ug/1
0.1 ug/1

0.001 ug/1
0.004 ug/1
0.01 ug/1
0.001 ug/1
0.004 ug/1

0.1 ug/1
0.03 ug/1
0.001 ug/1
0.04 ug/1
0.005 ug/1

6.5 to 8.5

± 1-0
1.0 ug/1

0.1 ug/1

Phthalate Esters

3.0 ug/1

3-11

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Table 3-3
WATER QUALITY CRITERIA
(Continued)

Parameter

Polychlorinated
Biphenyls

Radioactive
Subs tances

Class II

0.001 ug/1

Class III
Fresh
Chloride
Concentrate
<1.500 mg/1

0.001 ug/1

Class III
Marine
Chloride
Concentrate
>1.500 mg/1

0.001 ug/1

Radium 226 and

228
Gross Alpha

Selenium

Silver

Specific Conduc-
tance

Temperature

Transparency

Turbidity

Zinc

Alkalinity
Aluminum
Ammonia,

un-ionized
Antimony
Arsenic

<5 pCi/1
<15 pCi/1

25 ug/1

0.05 ug/1

90 F Max
Ambient +5 F

<10% reduction
from background

<29 NTU increase
from background

1.0 mg/1

1.5 mg/1

<5 pCi/1
<15 pCi/1

25 ug/1

0.07 ug/1

<5 pCi/1
<15 pCi/1

25 ug/1

0.05 ug/1

Shall not be in-
creased more than
50% above background
or to 1,275 umhos/cm,
whichever is greater

90 F Max
Ambient +5 F

0.2 mg/1
0.05 mg/1

<10% reduction
from background

<29 NTU increase
from background

30 ug/1

>20 mg/1 as CaCC>3
.02 mg/1

0.05 mg/1

Summer:

92 F Max
Ambient +2 F
Remainder:

90 F Max
Ambient +4 F

<10% reduction from
background

<29 NTU increase
from background

1.0 mg/1
1.5 mg/1

0.2 mg/1
0.05 mg/1

3-12

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Table 3-3
WATER QUALITY CRITERIA
(Continued)

Parameter

Beryllium

Biological
Integrity

Bromates
Bromine (Free

Molecular)
Cadmium

Chlorides

Chlorine (Total

Res idual)
Chromium, Total
(After mixing)
Coliforms, Fecal

Class II

Class III
Fresh
Chloride
Concentrate
<1.500 mg/1

Class III
Marine
Chloride
Concentrate
>1.500 mg/1

Shannon-Weaver
Diversity Index
(H) of benthic
macroinvertebrates
shall not be re-
duced to less than
75% of established
background

100 mg/1
0.1 mg/1

5.0 ug/1

0.011 mg/1
if hardness
<150 mg/1 CaC03
1.10 mg/1 if hardness
>150 mg/1 CaCC>3

Shannon-Weaver	—

Diversity Index
(H) of benthic
macroinvertebrates
shall not be re-
duced to less than
75% of established
background

0.8 ug/1

if hardness
<150 mg/1 CaCC>3
1.2 u/1

if hardness
>150 mg/1 CaC03

<10% increase over —
normal background
levels in predomi-
nantly marine waters

0.01 mg/1
0.05 mg/1

0.01 mg/1
0.05 mg/1

14 counts/100 ml 200 counts/100 ml
median; 43 counts/ monthly average;
100 ml	400 counts/100 ml

<10% of samples <10% of samples

per month; 800
counts/100 ml on
any one day

100 mg/1
0.1 mg/1

5.0 ug/1

<10% increase over
normal background
levels in predomi-
nantly marine waters

0.01 mg/1

0.05 mg/1

200 counts/100 ml
monthly average;
400 counts/100 ml
<10% of samples per
month; 800 counts/
100 ml on any one
day

3-13

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Table 3-3
WATER QUALITY CRITERIA
(Continued)







Class III

Class III







Fresh

Marine







Chloride

Chloride







Concentrate

Concentrate

Parameter



Class II

<1.500 me/1

>1.500 me/1

Coliforms,

Total

70 counts/100 ml

1,000 counts/100

1,000 counts/100 ml





median; 230 counts

ml monthly average;

monthly average;





<10% of samples

1,000 counts/100

1,000 counts/100 ml







ml <20% of samples

<20% of samples per







per month; 2,400

month; 2,400 counts/







counts/100 ml at

100 ml at any time







any time



Copper



15 ug/1

30 ug/1

15 ug/1

Cyanide



5.0 ug/1

5.0 ug/1

5.0 ug/1

Detergents



0.5 mg/1

0.5 mg/1

0.5 mg/1

Dissolved

Gases,

<110% saturation

<110% saturation

<110% saturation

Total









Dissolved

Oxygen

>5.0 mg/1 24 hour

>5.0 mg/1

>5.0 mg/1 24 hour





average; >4.0 mg/1



average; >4.0 mg/1





instantaneous



ins tantaneous

Fluoride



1.5 mg/1

10 mg/1

5.0 mg/1

Iron



0.3 mg/1

1.0 mg/1

0.3 mg.1

Lead



50 ug/1

30 ug/1

50 ug/1

Manganese



100 ug/1

	

	

Mercury



0.1 ug/1

0.2 ug/1

0.1 ug/1

Nickel



100 ug/1

100 ug/1

100 ug/1

Nutrients



Shall not be

Shall not be

Shall not be altered





altered so as to

altered so as to

so as to cause an





cause an imbalance

cause an imbalance

imbalance in natural





in natural popula-

in natural popula-

population of aquatic





tion of aquatic a

tion of aquatic

flora and fauna





flora and fauna

flora and fauna



3-14

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site. Velocities varied from 0.45 fps to 1.76 fps during flood tide and 0.43
to 1.79 fps and ebb tide. Flows varied from 40,000 cfs at flood stage to
29,000 cfs at ebb stage. On some occasions during a dry fall with strong
northeast winds, the river may reverse flow for a period of time.

Data collected over the past few years in the river showed that ambient
water quality concentrations of the following pollutants have been found to
exceed the State water quality standards for Class III marine waters:
aluminum, total residual chlorine, copper, total coliform, cyanide, iron,
mercury, oil and grease, and silver.

3.2.2	Broward River

Water quality data for the Broward River just upstream of its confluence
with the St. Johns River was obtained from the Jacksonville Department of
Health, Welfare And Bio-Environmental Services. Data indicates occasional
exceedances of State water quality standards criteria for pH, iron, lead, and
copper.

3.2.3	Surface Water Uses

The St. Johns River is under the jurisdiction of SJRWMD. The SJRWMD has
formulated policies to ensure a continued adequate supply of surface water for
various uses including public, industrial, power generation, irrigation,
rural, and recreational. Primary surface water uses in the site vicinity
include cooling, navigation, and recreation. Population growth in the region
as well as increased leisure time has resulted in a high demand for
recreational uses. The St. Johns River is a prime recreational resource.
Boating, water skiing, and fishing are enjoyed by both residents and tourists
in the area. The St. Johns River is also used for commercial navigation
serving domestic and foreign cargo lines at the Port of Jacksonville including
Blount Island as well as ports up stream as far as Sanford.

3-15

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3.2.3.1 Water Withdrawal

Total freshwater use in the Lower St. Johns River Basin (from Lake
St. George to the Atlantic Ocean) in 1975 was estimated to be 398.8 mgd. Of
this total, groundwater use was estimated to be 213.2 mgd and surface water
use was estimated to be 185.6 mgd. In 1975, nearly all freshwater consumption
for rural water use, irrigation, and public drinking water supply was
developed from groundwater resources, principally from the Floridan aquifer.
In 1986, a total of 133.72 mgd was withdrawn from the Floridan aquifer for
power generation uses. A significant portion of water use for industry and
power generation was developed from surface water sources, principally the St.
Johns River.

The Northside Generating Station, St. Johns River Power Park, and SK
paper mill are the major users of surface water from the St. Johns River in
the area. JEA withdraws approximately 806 mgd. The SK paper mill presently
uses up to 60 mgd for cooling purposes from the Broward River. Groundwater
uses are substantially less than surface water uses within a five mile radius,
although groundwater consumption represents a significant portion of total
water use at SK paper mill.

3.2.3.2 Water Discharges

When the CBCP goes into operation, the existing SK power boilers,
bark boilers, and chemical recovery boilers will be taken out of service. As
a result, the existing once-through cooling system will no longer discharge
30,000 gpm of heated water to the St. Johns River. The SK paper mill
currently discharges 13,900 gpm of wastewater from its industrial wastewater
treatment system (IWTS) to the St. Johns River. Table 3-4 is a summary of
proposed discharges for the CBCP during both construction and operations.

3-16

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Table 3-4

Summary of CBCP Wastewater Discharges

NPDES
Outfal I
Seri al
number

Type and Source of Wastewater

Flow Volune (MGD)	Receiving Waters

Construction Operations Construction Operati ons

001 o Main Plant Discharge via SK Discharge 2.88 (design) 1.150 (design)
System (receives effluent from OSN 002,

003, 005 and 008 (Construction flows only)

St. Johns

002	o Cooling Tower Blowdown to OSN 001

003	o Yard Area Runoff Pond Effluent

(includes construction runoff and roof
and yard drains) to OSN 001

.007 (avg.)
.500 (max.)

0.911 (avg.)

St. Johns

St. Johns

o Yard Area Runoff Pond (includes roof
and yard drains) to OSN 001

0.007 (avg.)
0.005 (max.)

St. Johns

004

o Emergency Overflow

o Boiler Blowdown to the Cooling Tower
for Reuse

N/A

N/A
0.157 (avg.)

Broward	Broward

St. Johns

005 o Construction Dewatering Wastes to	1.68 (avg.)

OSN 001 via the SK Once-through Cooling 2.88 (max.)
Water Effluent Line

St. Johns

006	o Pretreated Low Volume Wastes

(demineralizer regeneration, floor
drains,lab drains, and similar wastes)
and Discharge 007 to the SK IWTS

007	o Pretreated Metal Cleaning Wastes and

Nonchemical Metal Cleaning Wastes to
OSN 006 (1)

0.213 (avg.)

0.0 (avg.)
1.261 (max.)

St. Johns

St. Johns

008 o Coal, Limestone and Ash Storage Areas
Runoff Retention Basin Effluent to
OSN 001

.OK (avg.)

St. Johns

Coal, Limestone and Ash Storage Areas
Runoff Retention Basin Effluent to
the SK IWTS

0.0K (avg.)

St. Johns

o Emergency Overflow

N/A

N/A

Broward

Broward

(1) Flow will occur only during maintenance outages.

3-17

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3.3 GROUNDWATER RESOURCES

This section summarizes the groundwater resources in the Jacksonville

area.

3.3.1 Regional Groundwater Systems

Peninsular Florida's sedimentary rock sequences consist of about 8,000
feet of marine, littoral, and terrestrial deposits. The Paleozoic and
Mesozoic sequences comprise about 5,000 feet while Cenozoic strata extend from
the ground surface down to a depth of approximately 3,000 feet. The Cenozoic
sediments include the following geologic and hydrologic formations pertinent
to this project:

o The Cedar Keys Limestone which is the lowest confining
unit (aquiclude) for the Floridan aquifer;

o The Floridan aquifer which includes the Lake City Lime-
stone, the Avon Park Limestone, and the Ocala Group;

o The Hawthorn Formation which is the upper confining unit
for the Floridan aquifer; and

o The Choctawhatchee Formation.

The post-Miocene sediments in peninsular Florida are characterized by a
complex series of unconsolidated sands, clays, and shell. Where present,
undifferentiated upper Miocene and Pliocene sediments consist of poorly sorted
sands, gray clays, and shell beds with abundant mollusks. Pleistocene and
Holocene comprise the upper 10 to 90 feet in northern peninsular Florida.

These are yellow to tan sands with scattered thin clay layers. These
sediments contain a second important source of fresh water known as the
shallow aquifer system. This aquifer lies between the ground surface and a
depth of approximately 100 feet in the Duval County area.

3-18

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Two shallow aquifers underlie the CBCP site, the water table aquifer (-7
to -30 feet) and the shallow rock aquifer (-40 to -100 feet). They are
collectively referred to as the shallow aquifer system. The shallow rock
aquifer produces water that is generally acceptable for most domestic,
commercial, and industrial uses. Well yields in the shallow aquifer zone are
generally less than 100 gpm although yields of up to 200 gpm have been
reported. Water wells completed in surficial sands (water table aquifer)
generally yield less than 10 gpm. One well completed in a sand bed yielded in
excess of 40 gpm. Recharge to the shallow aquifer system occurs from rainfall
and surface water. Movement of ground water at the plant site is generally
towards the rivers (Broward River or St. Johns River). The water table
aquifer lies about seven feet below the ground surface in the plant area.

The CBCP site is underlain by the shallow aquifer system and the deeper
Floridan aquifer. The Floridan aquifer is encountered at depths ranging from
400 and 600 feet in the Duval County area and consists of two distinctly
separate zones referred to as the upper and lower permeable zones. The upper
permeable zone is the principle source of fresh water in Duval County.
Development of the lower permeable zone has been limited since adequate yields
of fresh water are obtained from the upper zone. Recharge to the Floridan
aquifer in this region occurs in western Putnam and Clay Counties and eastern
Alachua and Bradford Counties. Recharge occurs where rain and surface water
enter the Floridan aquifer through breaches in the overlying aquicludes.
Groundwater movement in the Floridan is from these recharge areas to the north
and east.

3.3.2 Groundwater Use

The Floridan aquifer is the principal source of fresh water for the
Jacksonville area. Users include utilities, private domestic water systems,
the military, commercial businesses and industry. In 1988, the Floridan
aquifer provided approximately 163 mgd for Duval County. A breakdown of
groundwater use in the surrounding area includes the following estimates:

3-19

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User

Amount (mgd)

Public Water Supply Systems
Other Domestic Uses
Industry

Agriculture/Irrigation
Thermal Electric

84.9

18.8

38.1

15.5

5.6

Total

162.9

The potentiometric surface for the Floridan aquifer in Jacksonville was
observed to be declining at a rate of 0.5 to 2.0 feet per year between the
1940's and 1962 due to increased pumping. Wells on Fort George Island to the
East of the site have shown evidence of salt water intrusion. Localized
depressions have been observed in the vicinity of Eastport and Jacksonville
where heavy pumping occurs. U.S. Geological Survey (USGS) files indicated in
1979 that the potentiometric surface near the site was about 35 feet above
mean sea level. Water levels (piezometric levels) in three nearby USGS
observation wells have varied from 41 feet to 32 feet NGVD over the last nine
years. The well grade elevations are approximately 16 feet NGVD. The
Floridan Aquifer at the project site is, therefore, free flowing artesian.
The SK wells flow at approximately 7,500 gpm at 9.5 psi pressure at the ground
surface.

The SJRWMD has prepared a report concerning the CBCP pursuant to
Paragraph 403.501 (l)(c), Florida Statutes. The report, which is included in
Appendix G, addresses only the consumptive use of water pursuant to Chapter
40C-2, FAC. The report identified 2 primary areas of concern regarding AES
proposed withdrawal plans. The first concern focused on the use of potable
groundwater for cooling tower make-up water (average flow of 3.99 MGD) and is
summarized in Section 2.4.1.2.2 of this document. The second concern relates
to the potential hydrologic impacts which could be caused by the applicant's
proposed well water withdrawals.

Addressing the second concern, SJRWMD required AES to perform a detailed
hydrologic investigation to determine the impacts of the proposed withdrawals
on existing legal users and the impacts to the groundwater resources itself.

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AES was required to use the USGS groundwater flow and transport models,

MODFLOW and MOC, to predict the impacts. SJRWMD required analyses for a
withdrawal rate of 7.0 MGD, the maximum projected at the site. This value
was to be evaluated because although reclaimed water is to be utilized as
cooling tower make-up, the district recognized that there may be times when
reclaimed water will not be available due to circumstances at the supply end,
and the CBCP could require up to 7.0 MGD of groundwater for power generation
and cooling. SJRWMD reviewed the modeling results presented in the report
entitled "Ground Water Investigation Report" for the CBCP which concluded that
the proposed withdrawals (7.0 MGD) for power generation and cooling tower
make-up will not cause adverse impacts to existing legal users or cause
adverse water quality problems.

SJRWMD also reviewed the potential for groundwater impacts due to
proposed dewatering withdrawals associated with the construction of the rail
car unloading facility. AES performed a hydrologic investigation to determine
the potential adverse impacts due to the temporary (9 months) construction
dewatering. AES concluded that the area of influence from the proposed
dewatering will not affect the existing legal users.

While it is recognized that the USGS flow and transport models, MODFLOW
and MOC are excellent models, they require a massive amount of work to
calibrate and run. The review process, by necessity, was limited to comparing
the output and predictions of the models to known or anticipated conditions.
An independent modeling effort has not been conducted by the State, the
SJRWMD, the City of Jacksonville, nor by EPA. Concerns relating to the
limitations of the models include the following:

o Because of the large area (10-1/2 by 18 miles) required to be

simulated in the models, a large grid size had to be used. This may
have masked significant localized effects, such as a possible
up-coning of salt water in the vicinity of the site, simply because
the models may not have used enough resolution to portray this
effect.

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o An assumption used in Che model was that the high chloride

concentrations (up to 3000 mg/1) in the lower water bearing zone
(LWBZ) are effectively separated from the upper water bearing zone
(UWBZ) by two, continuous aquicludes. Normal faults (Page 4-2 of
AES-CB "Ground Water Investigation Report") were neglected in the
model because they do not have any major effect on the flow system
of the aquifer (Miller, 1982). On a smaller scale, would these
faults allow chloride contamination to increase in the UWBZ, given
the effects of proposed on-site pumping?

o The ratio of vertical conductivity to horizontal conductivity used
in the MODFLOW model varied between 0.05 and 0.0002. These values
are significantly lower the typical literature values. These lower
ratios reflects a slower rate of flow and therefore permit the model
to simulate a lower potential for brackish water to move from the
LWBZ to the UWBZ. Additional information is needed to document the
values of vertical conductivity that were used in the MODFLOW model.

o It appears from the modeling report that existing pumpage rates were
used rather than the full permitted pumpage rates for the existing
permitted uses. The modeling effort should address the full
permitted rates in order to evaluate the impact of a "worse-case"
scenario.

o The piezometric head of the Floridan aquifer in the area has shown a
regional decline of about 1/2 foot per year for the last 40 years.
To have the model project these head drops into the future, it would
be necessary to construct a time variable constant-head boundary
condition. The MODFLOW modeling of the study assumed constant head
boundary conditions for the 40-year simulation period which could
bias the piezometric head in the UBWZ.

The recommendation of this EIS is that sensitivity analyses be conducted
to evaluate the effects of these concerns. These analyses should investigate
the effects of:

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o Incorporating the simulation of faults into the MOC model to show
the effect of more rapid flow between the LWBZ and the UWBZ. Flow
through hypothetical faults could be added to the LWBZ to UWBZ flux
(leakage) that was estimated for the MOC model.

o Increasing vertical conductivities by one to two orders-of-
magnitude.

o Increasing existing user pumping rates to reflect full permitted
values.

o Decreasing the piezometric heads at MODFLOW boundaries.

Also a more detailed technical summary of the groundwater modeling should be
prepared to off-set the fact that independent modeling was not performed.

Concern was also expressed that the modeling effort did not consider the
impacts of other future withdrawals by new users which would occur around the
site. This is not the responsibility of AES without specific information from
SJRWMD about what these withdrawals may be. It is recommended that SJRWMD
estimate the impacts of future withdrawals by new major users based on
anticipated applications. These estimates should be provided to AES for input
into the modeling effort described above.

3.3.3 Groundwater Quality

State water quality standards for groundwater are contained in rules of
the FDER Chapter 17-3, FAC Sections 17-3.401 to 17-3.404 and 17-22.104. These
standards state that "all groundwater with total dissolved solids of less than
10,000 mg/1 are classified as Class 1-B." The water quality criteria (Table
3-5) for Class 1-B are to be applied except within zones of discharge.

The quality of the water from the Floridan aquifer is variable depending
on the sampling location, sampling depth, and date of sampling. Contaminants
such as hydrogen sulfide gas (1-3 mg/1) and chlorides (10-30 mg/1) have been
found in wells in the Floridan aquifer in Duval County. Increases in chloride
concentrations have been documented in several high yield wells and are

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Table 3-5

STATE AND FEDERAL GROUNDWATER QUALITY CRITERIA3

USEPA Drinking



State of Florida b

Water

Standards c

Cons ti tuent

Class I-B Waters

Primary

Secondar

Inoreanic:







Arsenic

0.05

0.05



Barium

1.0

1.0



Cadmium

0.01

0.010



Chloride





250

Chromium

0.05

0.05



Color





15

Copper

1.5<*



1

Fluoride

1. 4 - 2.4e



Foaming Agents





0.5

Iron





0.3

Lead

0.05

0.05



Manganese





0.05

Mercury

0.002

0.002



Nitrate (as N)

10.0

10.0



Odor





3

pH





6.5-8.

Selenium

0.01

0.01



Silver

0.05

0.05



Sulfate





250

Total Dissolved Solids





500

Zinc





5

Radioactive Substances:







Radium (226f + 228)

5

5



Gross Alpha

15

15



Organic Chemicals:







Endrin

0.0002

0.0002



Lindane

0.004

0.004



Methozychlor

0.1

0.1



Toxaphene

0.005

0.005



2, 3-D

0.1

0.1



2, 4, 5-TP

0.01

0.01



a All values in milligrams per liter (mg/1) except color which is in color
units, odor which is in odor units, pH which is in Standard Units, and
radioactive substances which are in picocuries per liter (pCi/1).
b Florida Administrative Code, Chapter 17-3, March 1, 1979.
c Environmental Protection AgencyNational Interim Primary and Secondary

Drinking Water Regulations; 40 CFR Parts 141 and 143, as amended,
d 1.5 mg/1 or background levels, whichever is greater,
e Specific limit depends upon average maximum daily temperature,
f Including radium 226; excluding radon and uranium.

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attributed to high rates of pumping which cause a distinct cone of depression
and lower the potentiometric surface. Chloride concentrations increased
during the 1940 to 1962 time period due to heavy pumping. Wells penetrating
permeable zones deeper than the Ocala Group generally have higher chloride
concentrations because there is less hydrologic separation from the inferior
quality water within the Cedar Key Limestone and underlying formations. In
some areas, however, confining beds may retard movement between the zones of
high and low salinity.

Testing of water samples from Floridan aquifer wells on or near the SK
paper mill indicate that the water is of the calcium bicarbonate type. SK
well No. 2 showed increases in concentrations of sodium, conductivity,
dissolved and total solids in the 1972-1975 time period. That well displayed
higher values than other wells located at a greater distance from the River.
Sampling in 1983 also indicated that the conductivity in Well No.'s 1 and 2
had significantly higher conductivity values than other wells tested.

Water in the "shallow-rock" aquifer and the intermediate sand zone at the
site is also of the calcium-bicarbonate type. Some sodium and chloride ions
are present as a higher percentage of the total ionic weight in the water.
Water in the water table aquifer has a lower concentration of total dissolved
solids than that of deeper aquifers and other shallow aquifers. In general
water produced from the water table and shallow rock aquifer has a quality
that compares favorably with both State criteria for Class 1-B waters In the
instance of the SK property, however, the long term accumulation of spent lime
mud has led to contamination of the shallow aquifer. The pH has been elevated
in some areas. Metallic ions such as zinc, mercury arsenic, cadmium,
chromium, and lead show values in excess of State water quality criteria.
Copper and nickel levels are elevated as is phenol and certain hydrocarbon
compounds due to oil spills on site.

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3.4 EARTH RESOURCES

This section includes descriptions of the existing local and regional
physiography, topography, soils, and geology of the CBCP site. The site is
located in the St. Johns River Basin, an elongated area of approximately
51,200 square miles in northeast Florida. The area is underlain by limestone
and sands of Pleistocene to Eocene age and the surface is generally comprised
of sands and gravels of Pleistocene and Holocene terrace deposits. The
terrace deposits parallel the shoreline and form the topography of northeast
Florida.

3.4.1	Physiography and Topography

Florida can be divided into three major transpenninsular physiographic
zones: the Northern or Proximal Zone; the Central or Mid-peninsular Zone; and
the Southern or Distal Zone. The CBCP site is in the Northern Zone. The
topography of the site is controlled by Pleistocene marine terraces and beach
ridges bordered by tidal marsh and estuaries of the St. Johns River. The site
topography is gently sloping from the northeast to the southwest with surface
elevations varying between 20 feet and sea level. Surficial deposits are
sands, silty sands, and clayey sands to depths of 55 to 80 feet.

3.4.2	Soils and Geotechnical Conditions

Borings made on site show that the natural deposits are very erratic. In
some areas the site has been used to store lime mud and wood chips. Borings
show that these materials may be as much as 19 feet deep, overlying the
natural soils. Natural soils are medium to dense sands and silty sands that
vary greatly with depth and from one location to another, typical of marine
terrace deposits. These soils are about 80 feet deep and overlie the
Hawthorne formation. The Hawthorne formation consists of interbedded sandy
clays, clayey sands, and limestone. It serves as the Floridan aquifers
confining unit. Due to the high water table (three to eight feet below ground
level) and the loose, unconsolidated nature of the soils, special construction
techniques will be necessary to provide a firm foundation.

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Foundations for heavy structures may be a combination of friction and
bearing piles, driven into the dense sands or the Hawthorne formation. More
lightly loaded structures could be placed on shallow footings, mats, or piles
as necessary. Site improvements using ground modification techniques, such as
deep dynamic compaction, vibroflotation, or vibro-replacement are
possibilities to reduce or eliminate deep foundations. Removal of lime mud
and wood chips will also be necessary.

3.4.3	Regional Geology

Peninsular Florida is part of the Eastern Gulf Coast Sedimentary Basin
with a sedimentary sequence of limestones, dolomites, evaporites, and
unconsolidated sands, gravels, and clays that ranges in depth from 8,000 feet
in northern Florida to 18,000 in the southern portion of the state. These
strata are of late Mesozoic to Recent ages. The present land surface is
covered with Pliocene and younger unconsolidated sediments resulting from
fluctuations in sea level. They are generally marine terrace and beach ridge
deposits. Eocene and younger rocks comprise the strata encountered at the
surface and are penetrated by most water wells in the area. The principal
aquifers used in the Jacksonville area are of Eocene or younger age.

3.4.4	Site Geology

The site is covered with unconsolidated sediments of the Pleistocene to
Recent age that are primarily marine terrace and beach ridge deposits. These
sands and gravel overlie Mio-Pliocene deposits and the Hawthorne formation.
The Mio-Pliocene strata consist of semi-consolidated sands, gravels, shells,
and clay materials. The Hawthorne formation is the upper confining layer for
the Floridan aquifer in most areas and consists of clays, sands and some
limestones.

Uncomfortably beneath the Hawthorne formation lies the Ocala Group. A.t
the site the Ocala is approximately 450 feet deep. The Ocala Group overlies,
in descending order, the Avon Park Lime-stone, the Lake City Limestone, and
usually the Oldsmar Limestone. These strata are limestones and dolomites,
generally very permeable, and yield high quantities of groundwater. 3.5

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AQUATIC AND TERRESTRIAL ECOLOGY

This section provides a summary of the existing biological resources in
the vicinity of the CBCP site. Since the CBCP site area is presently in use
by the SK paper mill, onsite terrestrial resources are limited.

3.5.1 Aquatic Ecology

The proposed CBCP site is adjacent to the extreme northern portion of the
St. Johns River. Aquatic communities near site are typical of southeastern
estuaries, but are currently stressed by poor water quality caused by elevated
nutrient and pollutant loadings. Aquatic plants important to the ecology of
the estuary include phytoplankton, periphyton, and emergent marsh vegetation.
These primary producers support animal life within the estuary either directly
or via production of detritus (dead plant material). Aquatic animal life in
the area includes zooplankton, benthic invertebrates, fish, and marine
mammals, including an occasional manatee. Although stressed by poor water
quality, the St. Johns River in the vicinity of the SK paper mill is
nevertheless a highly productive estuarine area.

The CBCP will discharge its liquid effluents via the existing SK
discharge system. Therefore, the SK discharge is considered as part of the
existing environment. The CBCP will slightly change the chemical
concentrations of the combined discharge. Thus elimination of once-through
cooling water flow and the use of the recirculation cooling towers by CBCP
(with groundwater make up) will eliminate the negative impacts on aquatic
organisms due to entrainment and impingement. Additionally, the thermal
impact will be significantly reduced. When CBCP begins operation, SK will
purchase process steam from CBCP and will eliminate its existing steam boilers
and associated once-through cooling water system.

3.5.1.1 Flora

Phytoplankton are the most important primary producers in the open
waters of the St. Johns River estuary. Densities, rates of production, and
species composition of phytoplankton populations all indicate that the River
is subject to excessive nutrient and pollutant loadings. It has been reported

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(USCOE, 1976) that diatoms were the most abundant phytoplankton in waters of
Duval County. Studies at the JEA Northside Generating Station a few miles
east of the site, showed that phytoplankton communities were dominated by
pennate and centric diatoms, dinoflagellates, and cryptomonads with occasional
reports of green and bluegreen algae blooms (JEA 1976) . JEA (1976) indicated
that total densities of algae ranged from 200 to 6,750 organisms/ml during a
one-year study period. Periphyton populations in the upper St. Johns River
are composed primarily of diatoms (Weston, Inc. 1978). Periphyton are
important primary producers in area salt marshes (JEA/FP&L 1981a).

Tidal salt marshes border the CBCP site on both the south and east
sides. The dominant emergent plants in these areas are black needlerush
(Juncus roemerianus) and salt marsh cordgrass (Spartina alterniflora; S.
patens). Areas of the Broward River and the St. Johns River in the vicinity
of the CBCP site are bordered by narrow marshy areas with growths of black
needlerush and cordgrass. Extensive undisturbed tidal salt marshes also
border Dunn's Creek to the east of the site. Submerged aquatic vascular
plants occur in seasonally flooded wetlands on one small area of the site
site. Tidal salt marsh communities provide nursing, spawning, and/or feeding
habitats for many species of commercially important fish and shellfish. Salt
marshes also produce large amounts of dead plant material (detritus) which
supports the estuarine food web. These communities also maintain the
ecological balance of the estuary by helping to filter pollutants, nutrients,
and sediments which otherwise might flow directly into sensitive nursery and
spawning grounds. Wetlands also act as aquifer recharge zones and help to
maintain salinity patterns.

3.5.1.2 Fauna

Zooplankton. The principal zooplankton in the St. Johns River
estuary are copepods of the genus Acartia, cladocerans, larval forms of
benthic animals (primarily barnicle nauplii and cypris larvae), arrow worms
(Sagitta sp.), and mysid shrimp (JEA/FP&L 1981a). Zooplankton are an
important intermediate component of estuarine food webs. They are preyed upon
intensively by many commercially important species (e.g., menhaden) as well as
by non-commercial but ecologically important fishes (e.g., anchovies,
silversides) .

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Macroinvertebrates. Benthic macroinvertebrat^ populations in the
study area are dominated by polychaetes, obligochaetes, and small crustaceans
(JEA/FP&L 1981a). Benthic population densities in the Vicinity of the site
are generally low with scattered, high density patches <|>f several
opportunistic species. Benthic invertebrates are consumed by redfish, sea
trout, croakers, and many other predators.

Oysters, shrimp, and crabs are abundant in the St. Johns River
estuary. Commercial shrimp and blue crab spawn offshore and move into tidal
creeks and salt marsh areas of the St. Johns River near the site where they
grow and mature. Commercially important species include white shrimp (Penaeus
setiferus), brown shrimp (P. aztecus), pink shrimp (P. duorarum), and blue
crab (Callinectes sapidus). A limited number of oysters are commercially
harvested from a small area in northeast Duval County (USCOE 1980). The FDER
has not approved the St. Johns River in Duval County for shellfish harvesting,
however (JEA/FP&L 1981a).

Fish and Ichthyoplankton. The St. Johns River estuary supports an
abundant and varied fish community both seasonal and permanent residents of
the estuary (mummichog, menhaden, weakfish, perch, spot, spotted seatrout),
anadromous species (shad, striped bass), occasional oceanic species (bluefish,
tarpon, jacks) and strays from freshwater areas (gars, catfish). Freshwater
creeks, tidal creeks, and the St. Johns River have been previously surveyed in
the vicinity of the site (JEA/FP&L 1981a). This study lists 113 fish species
of fish from the estuarine portion of the St. Johns River. Many of these
species are commercially important and use the area near the site as spawning
and nursery grounds during different seasons of the year. The availability of
these areas is essential to the maintenance of a visible commercial fisheries
industry.

3.5.2 Terrestrial Ecology

Northeastern Florida falls within the southern mixed forest category as
defined by Kuchler (1964). The region is characterized as a tall forest with
broadleaf deciduous and evergreen species. Dominant trees are sweetgum,
southern magnolia, slash pine, loblolly pine, and oaks. The following
discussion deals with the proposed site. Communities on most of the
surrounding CBCP site have been either highly disturbed or eliminated.

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3.5.2.1 Site Area Vegetation

The proposed project site is located on industrialized land which
has been used for pulp mill operations for at least 30 years. During that
period alteration of the natural vegetation of the area has occurred with the
exception of the northern portion where there exists habitat suitable to the
gopher tortoise. The majority of the onsite vegetation consists of a mix of
annual and perennial weedy invasive species. A narrow band of trees has grown
up along the bank of the Broward River. A majority of the site is covered by
weedy species such as briar, ragweed, dog fennel, and Bermuda grass. Shrubby
grounsel trees occur along the river and on certain isolated portions of the
site. Other species in shrubby wooded sections consist of black cherry, wax
myrtle, and cabbage palm. Along the shore of the Broward River is a
Spartina-Juncus marsh.

3.5.2.2	Site Wildlife

Onsite wildlife habitat is limited, scattered in small patches, and
is of poor quality. Wildlife use of the site is limited to those species
which are able to adapt to human activity and a disturbed, industrial
environment. Animals observed on site include rabbits, snakes, tortoises, and
armadillos. Raccoons, skunks, mice, and opossums are likely onsite. Due to
lack of useful habitat, larger mammals such as deer may only occasionally
visit fringe areas of the SK paper mill site.

3.5.2.3	Biologically Sensitive Areas and Resources

Biologically sensitive areas on the CBCP site include the
Spartina-Juncus marsh bordering the river and habitats for rare, threatened,
or endangered species. The marsh system bordering the Broward River is a part
of the estuarine system of the St Johns River. It provides habitat for
breeding and nursery functions for aquatic organisms.

According to the Florida Natural Areas Inventory, there are no
records of federally or Florida listed threatened or endangered species
onsite. However, the West Indian Manatee, a federally and Florida endangered
species, inhabits the waters of the St. Johns River and has been observed in

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the Broward River. On the northern portion of the SK site occurs habitat
suitable for the gopher tortoise. The gopher tortoise harbors in its burrows
at least 30 types of commensal animals, including the indigo snake. It is a
federal C2 candidate species and a species of special concern in Florida.

Avian species of concern that may visit the site include Bachman's sparrow,
snowy egret, Louisiana or tricolored heron, and the red cockaded woodpecker.
The American alligator inhabits ponds, lakes, and rivers. It may potentially
be onsite near the river or north of the site in a small wetland area. Due to
a recent increase in population it has been reduced in rank to a federal
listing of "threatened due to similarity of appearance" and a Florida listing
of special concern. Its superficial resemblance to the rarer American
crocodile has resulted in its current continued federal listing.

Shallow freshwater, brackish, and saltwater wetlands are the
habitats of wading birds such as the little blue heron, snowy egret, and
Louisiana heron. These wading birds are species of special concern to Florida
and may utilize the shallow waters and low-tide mudflats near the proposed
site. The water adjacent to the site may also be a hunting area for osprey.

No rare, threatened or endangered species of vegetation are found on

site.

3.6 CULTURAL RESOURCES

Cultural resource data, including comments from the State Historic
Preservation Officer (SHPO) of the Florida Department of State Division of
Historical Resources (FDS DHR), were available to describe the existing
environment at the proposed CBCP site.

3.6.1 CBCP Site

The CBCP site is located within the Northern St. Johns Archaeological
Area. This region between the mouths of the St. Johns and St. Marys Rivers is
referred to as a transition zone between the Georgia Coastal tradition and the
St. Johns tradition of East Florida (Wood and Rudolph 1980b). Many of the

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recorded prehistoric shell middens and mounds along the St. Johns River have
been destroyed by residential and industrial development (FDAHR 1980).

Sources of information on the project area include the 1976 cultural resource
survey of Duval County (FDAHR 1980), a cultural reconnaissance report (Wood
and Rudolph 1980a), a report of the testing of eleven archaeological sites
(Wood and Rudolph 1980b), and the applicants' SCA/EID (AES/SKC 1988). These
sources indicate no presence of an archaeological district within the project
area which would be eligible for nomination to the National Register of
Historic Places (Percy/Tesar 1988) .

Site - specific cultural resources information for the CBCP site was
requested from the Florida SHPO. The SHPO stated in a letter dated August 4,
1988:

"A review of the Florida Master Site File indicates that
no significant archaeological and/or historical sites are
recorded for or considered likely to be present within the
project area. Therefore it is the opinion of this office
that the proposed projects will have no effect on any sites
listed, or eligible for listing, in the National Register
of Historic Places, or otherwise of national, state, or
local significance. The project is consistent with the
historic preservation aspects of Florida's coastal
zone program, and may proceed without further involvement
of this agency."

3.7 EXISTING SOCIAL AND ECONOMIC CONDITIONS

The analysis of existing socioeconomic conditions focuses primarily on
the CBCP region. Because the locations associated with the other alternatives
are not limited to specific sites or communities, the socioeconomic analysis
of existing conditions is restricted to this region.

The primary impact area of the CBCP project is considered to be the City
of Jacksonville and Duval County. This area will be referred to as the
project area. The six surrounding counties which include Baker, Clay,

Flagler, Nassau, Putnam, and St. Johns Counties are considered to be secondary

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impact areas and will be referred to as the	project region. The following
analysis identifies the existing social and economic conditions of both the

project area and project region which could	be affected by the proposed CBCP
proj ects.

3.7.1. Population Levels

The population of Duval County has grown rapidly during the 1980s,
primarily because of increased immigration to the area, and this growth is
forecast by JPD to continue. The total population in 1987 was 670,688, an
increase of almost 100,000 from 1980. The annual growth rate for the area
population has been 2.49 percent, double the rate of the 1970s. The
geographical pattern of growth has been uneven during this period, with the
largest gains in the southeast regions of the county, and estimated decreases
in population in the urban core. The estimated annual rate of growth in the
Southeast district from 1980-87 was 5.76 percent, versus 3.21 percent in the
North district (where CBCP will be located) and negative 0.63 percent in the
urban core. Much of the expansion has been due to a large increase in
opportunities for white-collar workers in the service sector. Another major
factor in the population growth has been the further development of three US
Navy bases located in the county.

Table 3-6 presents the population profile of Duval County for the
period 1980-87, showing the population trends for each of the districts in the
county. These data are from the US Department of Commerce and from JPD.

Table 3-7 provides estimated population figures for 1988 and 1990 for
districts within the county. The estimates for 1988 are obtained by
extrapolating the 1987 population estimates by the 1980-87 average annual
population growth rate for each of the districts. The population projections
for 1990 were prepared by JPD.

JPD has forecast that the population growth of Duval County will
continue through the year 2010, with an average annual growth rate (in the
period 1980-2010) of 1.50 percent.

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Table 3-6

Population Estimate for Duval County, Florida, by Planning District and Municipality
(April 1, 1987)

1980 Actual 1987 Estimated
Population*	Population

1980-87	1980-87	Average Annual

Net Change Percent Change Percent Change

Duval County

571,003

670,688

99,685

17 .46

2 .49

Planning Districts

North District	33,408
Greater Arlington Dist. 110,286

Southeast District	95,753

Southwest District	102,861

Northwest District	142,317

Urban Core District	56,295

40,912
136,497
134,380
121,793
147,056
53,831

7 , 504
26,211
38,627
18,932
4,739
-2 .464

22 .46
23.77
40. 34
18.41
3. 33
-4. 38

3 . 21
3 .40
5 . 76
2.63
0.48
-0. 63

City of Jacksonville

540,920

634,469

93,549

17 . 29

2 .47

Atlantic Beach
Baldwin

Jacksonville Beach
Neptune Beach

7,847
1,526
15,462
5,248

10,901
1,612
17,649
6 ,057

3,054
86
2,187
809

38.92
5.64

14	.14

15	.42

5.56
0. 81
2.02
2. 20

Other Municipalities

30,083

36,219

6,136

20.40

2.91

SOURCE: (*) US Department of Commerce, Bureau of; the Census, 1980 Census of: 1'opul.nLi.on and Housing

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Table 3-7

Population Projections for 1988 and 1990

1988 Estimated
Population

1990 Projected
Population

Duval County

687,388

690,354

Planning Districts

North District	42,225
Greater Arlington

District	141,137

Southeast District	142,120

Southwest District	124,996

Northwest District	147,761

Urban Core District	53,491

43,187

139,988
144,601
127,294
147,876
51,101

City of Jacksonville

650,140

654,047

NOTES:

1. 1988 population estimate based on extrapolating 1987 JPD estimate by
1980-87 growth rate.

2. 1990 projected population prepared by JPD.

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3.7.2 Economic Conditions

It is expected that the area principally affected by CBCP will be
Duval County. The data included in this section were collected from several
sources, including the 2005 Development Plan for Duval County, the North
District Plan, the 1987 Northeast Florida Comprehensive Regional Policy Plan
the 1980 Census of Population and Housing for Jacksonville, and the 1987
Annual Statistical Package prepared by the Jacksonville Planning Department.

3.7.2.1	Employment

The increase in population in Duval County has been parallele
by a dramatic increase in employment. During the period 1980-87, nonagricul
tural employment grew by 32 percent, from 288,600 persons to 382,200 persons
The rate of unemployment has ranged from a low 5.0 percent in 1980 to 7.8
percent in 1983. It currently stands at 5.2 percent (August 1988). Table 3
provides a sector-by-sector analysis of employment from 1980-87 to give a
clearer picture of the employment trends in the county. The dramatic
expansions for construction activity, retail trade, and services are an
indication of the economic growth of the area. Manufacturing and wholesale
trade employment has not kept pace with the growth of the county's economy,
indication of the trend toward service-based industries. Employment in the
Government sector grew slightly during this period, primarily because of the
continued development of the naval bases.

3.7.2.2	Income

The growth in the level of household income in Duval County
from 1970 to 1980 is detailed in Table 3-9. In 1980, an estimated 12.7
percent of families in Duval County had incomes below the poverty line. The
1985 per capita income was $10,565, an increase of 55 percent from 1980.

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Table 3-8

Employment Trends in Duval County, Florida
1980 to 1987

Employment Sector

1980

Number of Jobs

% of
Total

1987

% of
Total

Percent
Increase

Construction	15,500

Manufacturing	34,100

Transportation	23,700

Wholesale Trade	22,600

Retail Trade	51,700
Finance, Insurance

and Real Estate	27,200

Services and Mining	60,400

Government	53.400

5.4

11.8
8.2
7.8

17.9

9.4
20.9
18.5

27,200
38,000
27,200
27,800
75,200

36,300
93,000
57.500

7 .1

9.9
7.1
7.3
19.7

9.5
24.2
15.0

75 . 5
11.4
14.8
23.0
45.4

33 . 5
54.4
7.6

Total County

288,600

382,200

32.0

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Families

Households

Table 3-9

Household Income in Duval County, Florida

1970

1980

Percent
Change

Median
Mean

8,671
9,931

17,661
20,784

103.7
109.3

Median
Mean

6,642
8,039

14,938
18,377

124.9
128.6

Per Capita
(Age 15+)

2,834

6,822

140. 7

SOURCE: 1980 Census of Population and Housing, Jacksonville SMSA,
US Department of Commerce, Bureau of the Census, 1983.

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3.7.2.3 Housing

This section presents a profile of the existing housing stock,
along with trends in housing construction since 1980, the average size of the
household, and finally the stock of housing for the next two decades. Data
for this section are largely drawn from the 1987 Statistical Package prepared
by JPD.

The profile of the existing housing stock is summarized below:







Net

Percent



1980

1987

Chance

Change

Single Family

142,310

161,482

19,172

13.47

Duplexes

6,811

7,753

942

13.83

Tri/Quad-plexes

9,841

16,286

6,445

65.49

Five or More

41,562

54,333

12,771

30.73

Mobile Homes

13,032

23,461

10,429 '

80.03

Demolitions

0

-1.802

-1.802

_ _

Total

213,556

261,512

47 ,957

22 .46

The greatest percentage increase has been in mobile homes and multifamily
units; 53.49 percent of this new multifamily construction has been in the
Southeast District. A total of 92.9 percent of these new multifamily
dwellings have been built in three areas of the county; Southeast District,
Greater Arlington District, and Southwest District.

In addition to the dwellings listed above, there were an
estimated 21,966 seasonal units (transitory apartments, rooming houses, hotels
and campgrounds) in 1985, and this number was forecast to grow to 26,965 by
1995.

The average household size during this same period has declined
dramatically, from 3.35 persons per dwelling in 1980 to 2.6 persons in 1987.
This is a 22.4 percent decrease.

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JPD has forecast that housing stock in Duval County will
continue to grow, expanding by 60.6 percent by the year 2010, to a total of
363,831 units. A table summarizing the projected housing growth pattern is
included in Table 3-10. This continued growth is demonstrated by the number
of new building permits issued in the period from April 1987 through May 1988,
as follows:

Building Type	Number of Permits	Percent of Total

Single Family	4,550	61

Multifamily	2,071	28

Mobile Homes	837	11
SOURCE: JPD

3.7.3 Community Services

Minor project-related impacts on community services and facilities
are expected to occur in the Jacksonville/Duval County area. While there may
be some secondary impacts realized in other counties of the project region, in
is not expected that their public or private services and community infra-
structure will be directly affected by CBCP. Consequently, this analysis only
addresses the community services of Jacksonville/Duval County area.

3.7.3.1 Water Supply and Wastewater Treatment

The Jacksonville/Duval County public works service function
includes sewage, water, and sanitation services. At present, each component
is operating with excess capacity. The sewage component has a current design
capacity of approximately 87.41 mgd while the current wastewater flow is about
44.99 mgd or an excess capacity of approximately 42.42 mgd. The current
design capacity of the water treatment component is about 175 mgd while the
current demand is approximately 65.45 mgd or an excess of over 109.55 mgd.

City water is not available and, therefore will not be used by CBCP. The
current service level capacity of the sanitation component is 1.1 million
pounds per day (1980). Resident demand for this public service-function at
that time was about 864,000 total pounds per day. However, remaining space in
existing landfills is becoming critically small. At the present time, there
are two municipal landfills in operation. One of these was to be closed

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Table 3-10

PROJECTED HOUSEHOLD POPULATION AND DUELLING UNITS FOR DUVAL COUNTY, FLORIDA (1980-2010)



Population



Group Quarters







DwelIinq Uni ts



Vacancy

Year

Total

Household

Total

C i v iIi an

Mi Ii tary*

Household
Si ze

Total

Occupi ed

Vacant

Rate
Percent

1980

571,033

559,694

11,309

6,235

5,074

2.6863

226,611

208,151

18,260

8.06

1985

633,920

617,885

16,035

6,561

9,474

2.6093

258,518

236,799

21,719

8.40

1990

690,354

672,570

17,784

6,887

10,897

2.5611

285 , 756

262,610

23,146

8.10

1995

733,914

715,804

18,110

7,213

10,897

2.5098

310,747

285,204

25,543

8.22

2000

769,565

751,129

18,436

7,539

10,897

2.4659

332,285

304,606

27,679

8.33

2005

799,467

780,705

18,762

7,865

10,897

2.4289

351,090

321,423

29,667

8.45

2010

827,151

808,063

19,088

8,191

10,897

2.4289

363,831

332,687

31,144

8.56

U)

I

.p-
ho

* Includes only 28.32 percent of the personnel projected to be assigned aboard ships for N.S. Mayport basin (because the projected remainder has
another place of residence within 50 miles), and other unaccompanied personnel for all three naval facilities.

SOURCE: US Department of Comnerce, Bureau of Census, 1980 Census of Population and Housing (Jacksonville Planning Department, October 1985).

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in 1989. An application has been filed for a second landfill in the Southeast
District. It was expected to be opened in 1989. The county has also filed a
request for expansion of the present North District landfill. If both
requests are granted, the system capacity will be approximately 1.7 million
cubic yards of usable space.

3.7.3.2	Public Safety

The public safety service function includes law enforcement and
fire protection. Based on US Department of Commerce standards, the law
enforcement component for 1979-80 has adequate personnel to meet public demand
in the Jacksonville/Duval area. A city of this size reportedly requires 1,325
enforcement officers and support personnel to satisfy the public demand.
Jacksonville/Duval County currently has a staff of 1,485 which actually
represents an excess of 160 full-time personnel (JEA/FP&L 1981a). The
evaluation of the Duval County police facilities for the 2005 Comprehensive
Plan recommended the construction of a new jail and the possible construction
of new police stations, if a decentralized policy were adopted.

Within the North District, there are presently (1985) eight
fire stations, manned by a combination of paid and volunteer personnel. Two
of the facilities are manned only by volunteers. Structural conditions of the
facilities vary from fair for most stations to very good for the newer
facilities. Because of the large geographic area in the North District, very
few areas are serviced with an average response time of less than three
minutes from existing stations. This is expected to improve somewhat with the
relocation of one of the fire stations and the addition of new equipment. The
station is being moved from the Navy Fuel Depot to the intersection of Busch
Drive and North Main Street.

3.7.3.3	Education

The public school system of Jacksonville/Duval County area
consists of 132 schools and currently has the physical capacity to accommodate
an enrollment of approximately 104,300 students. The current physical
capacity of the school system in pupil stations is slightly more than 107,000,

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resulting in an excess of approximately 2,700 pupil stations. There are also
approximately 60 private and parochial schools located in Duval County. These
schools range from 3 grades to 13 grades (k-12) and include two special
education centers (Jacksonville Area Planning Board 1979 in JEA/FP&L 1981a).
The Jacksonville area also has several postsecondary educational institutions.

There was a decline in Duval County school enrollment during
the 1970's, but enrollment is expected to increase during the period of
1980-2000. In 1977-78, 14.5 percent of elementary school students and 12.5
percent of secondary students were enrolled in private or parochial schools.
If it is assumed that the percentage of students enrolled in these schools
remains constant in the future, then the forecast enrollment and capacity
needs for Duval County are as follows (data from the Duval County 2005
Comprehensive Plan") .

Elementary Schools	Projected Enrollment	Additional Schools

1980	49,582	2

1990	56,570	0

2005	65,200	8
Secondary Schools

1980	52,170	0

1990	52,273	0

2005	63,709	6

An alternative assumption is that the absolute number of students in non-
government schools remains constant. In this case, the number of additional
schools required would be slightly lower in some cases.

3.7.3.4 Health Care

Based on US Department of Commerce standards, a city of
Jacksonville's size should maintain a public health staff of approximately 750
personnel. At present, the public health service function of Jacksonville/
Duval County has a staff of only 165, resulting in a deficiency of
approximately 590 personnel (JEA/FP&L 1981a). One explanation for this public
health service deficiency could be the abundance of non-public health

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facilities (hospitals) in the city. The various private hospitals in
Jacksonville/Duval County are currently maintaining a service level of
approximately 1,065,000 patient days. With a current resident demand of about
779,200, this equates to a current excess of approximately 286,000 patient
days or a 73% capacity level. The capacity benchmark utilized by a majority
of the area's hospitals is 80% (JEA/FP&L 1981a).

It should be noted that, at present there is no hospital in the
North District of Duval County. The nearest two facilities are located
approximately 4.5 miles south on 1-95. These two hospitals (Methodist
Hospital, Inc. and the University Hospital of Jacksonville) are multipurpose
facilities. In addition, there are other hospitals farther from the District.
JPD has forecast the need for small-to-medium size facility to service the
needs of the expanding population in this North District.

There are numerous medical and dental private offices and
clinics in the District. The majority of these are located in the southern
and central portions of the North District.

3.8 LAND USES, RECREATIONAL RESOURCES, AND AESTHETIC CONDITIONS

This section addresses the existing land uses, recreational resources and
aesthetic conditions of the areas surrounding the CBCP site. Because the
other alternatives considered are not restricted to specific sites and
communities, a detailed analysis of existing conditions for any other affected
areas is not presented.

3.8.1 Cedar Bav/Cogeneration Project Area

The primary impact area of the CBCP is considered to be Jacksonville/
Duval County. This area is referred to as the project area. The six
surrounding counties which include Baker, Clay, Flagler, Nassau, Putnam, and
St. Johns Counties are considered to be secondary impact areas and are
referred to as the project region. Land use in the seven county project
region is predominantly agricultural with approximately 233,650 acres (82%)

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devoted to this use. Other land uses in the region include residential;
commercial; industrial; and extractive (Table 3-11). The greatest urban-
related use in the Northeast Region is residential land use (approximately
102.930 acres or 4%). Low density development are located primarily near the
St. Johns River and transportation corridors throughout the region. Medium
and high density residential areas are found along the coast and near downtown
Jacksonville as well as St. Augustine, Jacksonville Beach, and Atlantic Beach.

In contrast to the region, Duval County has only 58.8% of its land in
agricultural uses. The most predominant land use in Duval County is
residential comprising 58,247 acres (11.8%) while industrial institutional,
and commercial uses constitute 36,950 acres or approximately 9% of the total
land area (Jacksonville Area Planning Board 1977a in JEA/FP&L 1981a).

3.8.1.1	Existing Land Cover

Most of the land within the five mile radius of the proposed CBCP
site is within the North District of the City of Jacksonville. A total of
116,545 acres can be considered suitable for development. Of this total,
30,951 acres were covered with urban development in 1985. Of this urban
development, some 9997 acres is residential; mostly single family. Most of
the residential areas are south or west of the St. Johns River or west of Main
Street. Transportation facilities covers 9651 acres within this district.
Parks and recreational areas cover 4992 acres.

3.8.1.2	Existing Land Uses

The land use within a five mile radius of the proposed CBCP is
concentrated primarily in the northern half of Duval County located near the
St. Johns River. Land use in the vicinity of the proposed CBCP is highly
related to uses of the St. Johns River and is expected to continue in such
related uses (Table 3-12). Demands are heavy for that land which is easily
accessible to the river. These demands are primarily for industrial,
commercial, residential, and recreational land uses. Recent land use trends
in the vicinity of the site since 1985 can be ascertained from building permit

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Table 3-11

Existing Land Use Acreage - Northeast Florida Region
(Jacksonville area Planning Board 1977a in JEA/FP&L 1981a).

Baker Clay

2,568 11,382 58,247

84
83
3,849

845
674

4,284 20,677

C Lassi f ication

Residential a

Corrmercial &

Servi ces

Industrial

Transportation

Ccmmuni cat i on
& UtiIities

Insti tutional

Recreational c

Mixed

Extractive	182 3,891

Developed 7,674 91,126 125,909

Duval

County
Flagler Nassau

Putnam

5,754
4,819

321	175	843

315 67,991 26,378
1,884 6,660
318
2,214

161

1,774

244
110
3,296

39
188
264

7,316 10,304

5,916

416	534

300	545

5,167	4,288

42	1,145

255	729

1,861	525

63	430

76	666
15,495 19,166

St. Johns
11,234

740
446
54,564

176
673
791
11

Regi on
102,934

8,617
6,978
47,125

2,741
94,530
12,146
822
7,029

Total

19,637 284,922

Total Land Area 374,144 379,520 490,048 311,872 416,000 498,368 387,008 2,856,960

Developed as X
of Total Land

Agriculture

Agriculture as
of Total Land

2.1 24.0 25.7	1.9

357,562 346,971 288,240 282,378

3.7	3.8

348,452 379,452

95.6

91.4

58.8

90.5

83.8

76.2

5.1
333,306

86.1

10.0
233,652

81.8 a

a. Includes local streets right-of-way. b Includes an estimated 11,316 acres of rights-of-way.
c Excludes national forest and/or swamp lands and game management areas or refuge.

Note: Columns may not total exactly due to rounding.

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Table 3-12

Summary of Land Use Existing in 1985 in the Area Surrounding the Plant
(Census Tracts 102.01 and 102.02)(AES/SKC 1988)

Census Tracts

Percent

102.01	102.02	Total	of

Land Use		Acres	Acres	Acres	Total

Controls

Gross Area

5,565.24

5,777.92

11,343.16



Less Water

624.91

938.90

1,563.81



Less Salt Marsh

294.17

362.01

656.18



Net Land Area

4,646.16

4,477.01

9,123.17

100.0

rbanized Development









Single Family

1,089.70

436.32

1,526.02

16.7

Multi- Family

0

0.00

0.00

0.0

Parks and Recreation

36.05

77 . 39

113.44

1.2

Institutional

20.19

158.00

178.19

2.0

Commercial and Service

44.52

30.65

75.17

0.8

Communications and









Utilities

33.00

13.63

44.63

0.5

Major Transportation

186.90

316.85

503.75

5.5

Industrial

179.55

789.01

968.56

10.6

Total Urban Development

1,589.91

1,821.25

3,411.16

37 .4

Remaining Developable









Land

3,056.25

2,655.16

5,711.41

62.6

Source: Jacksonville Planning Department, North District Plan.
Jacksonville, Florida, June 1986.

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data for census tracts 102.01 and 102.02. These tracts are bordered by Duval
Station road on the north, by Dunn Creek on the East, by Main Street on the
West and by the St. Johns River on the South.

The proposed site is currently zoned for heavy industrial use which
may include, by exception, power plant siting. The land contiguous to the
north, east, and south of the proposed site is zoned industrial as well. The
Broward River is to the west of the site. Approximately 969 acres of the
total land in the two census tracts is currently identified as industrial use.

Industries are locating in this area not only because of the St.
Johns River, but also because of the proximity to interstate highways and the
Jacksonville International Airport. In 1985, 10.6 % of developable land in
Census tracts 102.01 and 102.02 was devoted to industrial use. Between 1985
and 1988, 24 building permits were issued for industrial sites in this area
representing over 44 acres of new industrial development. Most of this
industrial development occurred along Hecksher Drive, Eastport and Busch
Roads, and Main Street.

Residential land use constituted 16.7% of the developable land in
this area in 1985, encompassing 1526 acres and 2977 dwelling units. By
September of 1988, residential land use had expanded to approximately 18% of
the developable land area due to issuance of an additional 237 residential
permits, about 4 miles from the site. The closer residential areas are a
mixture of house trailers and single-family dwellings of varying conditions
and ages. The area farther from the site is separated by commercial districts
and consists primarily of well-maintained, middle to upper income dwellings.

In 1985, less than one percent of the developable land in Census
tract 102.01 and 102.02 was used for commercial or service activities.

Between 1985 and 1988, 72 building permits were issued representing over 57
acres of industrial development. this development occurred primarily along
Main Street, New Berlin Road, and Busch Drive, with some development along
Eastport Road and Hecksher Drive.

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3.8.1.3 Projected Land Uses

The Northeast Region is expected to experience an increase in
urban-related land uses as the decline in agricultural uses continues.

However, the growth of urban-related land uses is likely to occur in a
restricted pattern. Natural resource factors such as the availability of
adequate water supplies may condition the location of such future development.
Future land uses within the five mile radius are expected to continue focusing
on activities associated with the St. Johns River. Heavy demands are
projected for the shores of the river by industry, water-related commercial,
and residential land uses. The 2005 Comprehensive Plan by the Jacksonville
Area Planning Board calls for port- and water - related industry as well as
protected wetland areas in the vicinity of the proposed project (JEA/FP&L
1981a). The area along Heckscher Drive from Interstate 95 east to just north
of Blount Island is expected to continue developing as industrial and storage
facilities. By the year 2005, the area of the proposed CBCP should have
experienced major industrial development even without the proposed project.
Blount Island is expected to continue developing as a center for water-related
industries.

3.8.1.4 Existing Zoning

Land in the primary project area is zoned for industrial uses. The
proposed CBCP site has been zoned for heavy industrial use (IH). Power plants
are permissible uses in IH zones. A 1.9 acre portion of the original site is
zoned Open Rural (OR). The City Council declined to rezone this parcel.
Consequently AES deleted the 1.9 acre parcel from the site and added a one
acre parcel on the pulp mill property that was zoned IH. The paper mill's
existing wastewater treatment ponds are located on property zoned OR. The use
of the OR land for a wastewater treatment plant was allowed for the paper mill
as an essential service. Existing land use ordinances refers to a single
industrial use under the Essential Services definition. The City granted an
exception on March 16, 1989, to allow the wastewater treatment facility to
treat wastewater from the cogeneration plant. The Siting Board found the site
to be in compliance with local land use and zoning plans on June 27, 1989.

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3.8.1.5 Recreational Resources

Recreational areas in the region center around the coast and the
river. Within the five mile radius of the proposed CBCP is the Jacksonville
Municipal Zoo between two to three miles southwest of the site. Also within
this radius is Yellow Bluff Fort, an undeveloped State park at the site of
Confederate Army gun placements which were used in 1862 to protect
Jacksonville from Union gunboats. A number of areas also exist that are not
officially designated as parks. These areas are normally used for fishing,
sunbathing, and picnicking.

Between 7 and 10 miles from the proposed site are two regional
parks. One of these parks is the Kingsley Plantation, a State historic and
recreational site located on Fort George Island near the beaches. The
Jacksonville Area Planning Board (JAPB) estimates that over 35,000 people
visit the plantation each year (JEA/FP&L 1981a). Also located on Fort George
Island is the Rollins Bird and Plant Sanctuary. To the east is the 2,500 acre
Little Talbot Island State Park. This park provides beach recreation to over
35,000 visitors each year (JEA/FP&L 1981a). The Fort Caroline National
Memorial is located approximately eight miles southeast of the site. It is a
120-acre reconstruction of a French fort built in 1564. The JAPB estimates
that visitation to the fort averages around 400,000 people per year.

North of Jacksonville on the Florida/Georgia border is the
Okefenokee Swamp, a National Wildlife Area. The swamp is over 40 miles long
and 20 miles wide and contains abundant wildlife including rare species of
flora and fauna. Also located north of Jacksonville at St. Mary's, Georgia is
the Cumberland Island National Seashore. Cumberland Island is a National Park
offering camping, biking, swimming, and fishing in a natural wildlife setting.

3.8.1.6 Aesthetic Conditions

The site of the proposed CBCP is a relatively flat area on the
eastern shore of the Broward River and the western portion of an industrial
area. The general vista is open to the south and west due to the rivers. To
the south the vista is influenced by industrial development associated with
existing oil terminals. Adjacent to the proposed site is the Seminole Kraft

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Corporation paper mill. The existing view toward the proposed site is
dominated by the buildings and stacks of the paper mill.

The viewshed of the proposed site extends mostly to the south
because of the St. Johns River and the marshes. Homes located on the western
shore of the Broward River are most affected by the view of industrial
structures in the area. The only major road south of the St. Johns River that
offers a view of the industrial structures close to the proposed site is Fort
Caroline Road which runs contiguous up to the marshes and Mill Cove. On the
north side of the River south of the proposed site, a view of the proposed
CBCP will be possible from Heckscher Drive. This view is presently dominated
by the paper mill in the foreground and is typical of the industrialized
section of Heckscher Drive. East of the site, the tree cover allows only a
limited view of the structures.

3.9 EXISTING TRANSPORTATION

The study area of northeast Florida was considered in order to determine
the existing transportation facilities available to the proposed CBCP. The
study area includes the transportation facilities of Jacksonville, Florida
which will serve the proposed project.

Transportation systems of importance to the Jacksonville area are
highways, railroads, airports, and ship facilities (Figure 3-2). Major
highways include Interstate Highways 10 and 95 and US Highways 1, 17, 23, and
90. Three rail systems serve the area: the Southern Railway; the Atlantic
Coast Line Railroad; and the Seaboard Coast Line Railroad. Only the Seaboard
Coast Line (SCX) serves the Cedar Bay area. Major airports include
Jacksonville International Airport, Craig Airport, Herlong Airport, and the
Mayport Naval Air Field. Major port facilities include Blount Island and the
Talleyrand Docks and Terminals.

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REGIONALLY SIGNIFICANT
ROADWAYS AND RAILROADS

FIGURE 3-2

3-53

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Roads expected to provide access to the proposed CBCP site are Heckscher
Drive, Eastport Road, and Main Street. Traffic courts indicate that (under
existing conditions) all signalized locations and roadways in the area operate
at level of service C or better with additional capacity available. Level of
service C is defined as stable traffic flow where most drivers are restricted
in selecting their speed, but where all stopped traffic will clear a
signalized intersection. The intersection of 1-95 to Heckscher Road and its
intersection with Heckscher Drive going toward Main Street, however, is
congested during peak periods (JEA/FP&L 1981a).

Jacksonville International Airport is a major asset to the region. This
Airport provides commercial service directly to Atlanta and other southeastern
cities as well as to several other major airports. In addition, this Airport
provides general aviation facilities. It is the only civil airport in the
region that is capable of accommodating higher performance, more sophisticated
general aviation aircraft (JEA/FP&L 1981a).

Jacksonville functions as a major port facility serving the southeastern
United States. Port facilities include Blount Island and the Talleyrand Docks
and Terminals. Many Jacksonville industries are dependent upon barge and
oceangoing vessels for transportation of raw materials and finished products.
Port facilities serve as an asset in attracting new industries to the City.
The USCOE maintains a channel depth of 38 feet in the St. Johns River near the
project area (Moulding 1981).

3.10 SOUND QUALITY

This section describes the existing ambient sound environment for the
proposed site. The study area includes noise receptors that could be possibly
affected by noise from the CBCP. Noise sources in the area include roadways,
railroads, industrial plants, SK paper mill, and airports. A noise survey was
performed in March and July 1988, at three locations around the site. One
location was at the Junction of Eastport Road and the northeast entrance to

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Che Seminole Kraft paper mill site. Another location was at the junction of
Hecksher Drive and Eastport Road. The last location was in a residential area
along Cedar Bay Road. Existing noise levels are listed in Table 3-13. and
monitoring locations are shown on Figure 3-3. The noise receptor most likely
to be affected by the CBCP is site 3 located near residences along Cedar Bay
Road some 2,000 feet west of the site . Measured noise levels ranged from a
Leq of 46.3 dBA during nighttime hours to 65.7 dBA during daytime hours. Lraax
values ranged from 48.3 dBA during nighttime hours to 83.1 dBA during daytime
hours. While making measurements, insect noise, a sewage treatment plant and
the pulp mill were the most identifiable noise sources. The Cedar Bay Road
area would be the most sensitive area for plant induced noises. Other noise
sensitive locations would be residential areas along the rail line to the
northwest of the site.

There are no existing federal or state noise control regulations that
apply directly to offsite noise levels resulting from CBCP. Two local
ordinances regulating noise levels are applicable to CBCP, the Land Use
Regulations for the City of Jacksonville, Florida and the restrictions
established by the Jacksonville Environmental Protection Board. Daytime sound
levels caused by project construction are not expected to exceed any limits.
If nighttime construction is allowed, the noise level requirements may exceed
the 60dBA limit. AES simulated operation sound levels using a computer model
and information contained in a guidance document by the Edison Electric
Institute for estimating noise emissions from specific equipment. It was
concluded that the overall effect of the operational noise from CBCP on the
surrounding area will be acceptable.

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Table 3-13
EXISTING NOISE LEVELS

d8A

NHL*	Period	Day	T iine	Leq-	Lmax

1	Nighttime	3-10-88	1:20 a.m.	48.3	51.7

50.0	54.6
60.7	81.8

1	Daytime	3-10-88	10:55 a.m.	70.0	79.6

68.7	77.A

1	Nighttime	7-28-88	2:18 a.m.	66.2	75.3

64.2	67.8
63.6	67.7

1	Daytime	7-28-88	3:45 p.m.	68.2	78.0

64.5	73.8

64.6	70.7

f	2	Nighttime	3-10-88	1:35 a.m.	69.9	74.5

Ł	68.7	73.3

2	Daytime	3-10-88	10:35 a.m.	72.0	78.5

71.1	83.2

2	Nighttime	7-28-88	2:25 a.m.	63.3	65.2

63.5	65.2

64.6	70.9

2	Daytime	7-28-88	3:25 p.m.	76.5	93.2

59.2	65.7

69.0	83.1

3	Nighttime	3-10-88	2:10 a.m.	46.6	49.3

46.3	48.3

3	Daytime	3-10-88	11:20 a.m.	58.2	68.4

65.7	81.9

62.1	73.8

3	Nighttime	7-28-88	1:48 a.m.	51.6	53.3

51.6	53.1

51.5	54.7

3	Daytime	7-28-88	4:11 p.m.	49.9	55.8

49.0	50.8

53.3	57.7

Identifiable Sources

Paper mi 11 plant
Train horn

Train horn and two car passes in distance
Traffic on Heckscher Blvd., paper mill plant
Train horn, leaf rustling
Same as above

Generator for construction lights and arrows on nearby bridge
Traffic noise and generator
Same as above

Approximately 30 car and truck passes
Approximately 25 car and truck passes

Approximately 15 car and truck passes and airplane overhead
Paper mi 11 plant
Same as above

Paper mill plant, wind noise, flapping flag, auto traffic

Truck noise

Paper mi 11 plant

Paper mi 11 plant

Paper mi 11 plant

Paper mill plant, traffic

Paper mill plant, traffic

Paper mill plant, traffic

Paper mi 11, insects

Paper mi 11, insects

Wind noise, sewage treatment plant

Wind noise, sewage treatment plant

Wind noise, sewage treatment plant, one car pass

Insect noise, sewage treatment plant

Insect noise, sewage treatment plant

Insect noise, sewage treatment plant

Insect noise, sewage treatment plant, paper mill

Insect noise, sewage treatment plant, paper mill

Insect noise, sewage treatment plant, paper mill

* Noise Measurement Location. See Figure 3-3 for placement with respect to the plant.

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2000 1000

2000

Scdi tn Fmi

NOISE MONITORING LOCATIONS

FIGURE 3-3

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3.11 ENERGY RESOURCES

This section summarizes the energy situation in Florida.

3.11.1 Florida

3.11.1.1 Traditional Energy Sources

In 1987, the state of Florida relied on petroleum and natural gas for
59.3% of its energy needs. Petroleum constituted 48.2% and natural gas
constituted 11.1% of the total consumption of primary energy. Coal supplies
20.8% and nuclear 7.2% of Florida's energy needs. The state uses less coal,
natural gas, petroleum, and nuclear energy on a per capita basis than the
average U.S. citizen. Floridians used 26% less energy than the average U.S.
citizen in 1987. Part of this difference may be attributed to the lack of
heavy industry in the state. Since most of the energy in Florida must be
imported, industries which use less energy or renewable resources have a
competitive advantage over more energy intensive industries.

In 1987, coal supplied 23.6% of the nations energy, but only 20.8%
of Florida's. Nationwide, 84.3% of all coal consumption is for electric
generation, compared with 95.6% in Florida. The state's small industrial
sector uses relatively less coal. Florida purchased more interstate
electricity in 1987 then in previous years, a direct result of higher prices
for residual oil.

In Florida homes, air conditioning and water heating are the primary
electrical energy consumers. These uses consume a much higher percentage of
total residential energy than in other states. Conversely, heating of Florida
homes uses far less energy than the national average for heating (Florida
Governors Energy Office 1981).

In 1987, 41.5% of Florida's electricity was generated from coal,
more than any other fuel. Until 1984, petroleum was the primary generating
fuel. Petroleum supplied only 13.5% of the energy used for generation in
1987, compared to the high of 58.3% in 1972. Nuclear fuel provided another

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15% of the energy used for generation, while natural gas accounted for 13.6% ,
both down from 1986. The use of wood and waste as a generating fuel increased
significantly over the 1986 level.

Electricity produced by non-utility generators also contributes to
the state's total electric supply. Cogeneration is the combined production of
heat and electricity from one energy source. Heat and electricity can be
produced together at a lower cost than either alone. Several of Florida's
businesses and industries that use process heat also generate electricity.
Cogeneration can assist in providing an uninterrupted supply of power.

Cogeneration is encouraged by the Public Utility Regulatory Policies
Act of 1978 (PURPA P.I. 95617). This law requires utilities to purchase
electricity from qualifying cogenerators at mutually agreeable prices or at
the utility's avoided cost ("Avoided cost" is the energy and capacity costs
that a utility avoids by purchasing power from the cogenerator.) At this
time, Florida has over 800 Mw of cogenerating capacity. Net generation from
cogenerators totaled 8.5 million Btu during 1987.

Interstate purchases are an important component of Florida's
electric supply. Due to rising petroleum prices these imports increased 44.6%
from 1986, but still provided 14.6% of Florida's electricity in 1987.

Purchases of out-of-state electricity during 1987 totaled 65 trillion Btu.
The majority of interstate purchases are from coal-fired plants located in
Georgia, and are frequently referred to as "coal-by-wire."

Electric sales rose 5% in from 1986 to 1987, to a total of 122.128
GWh. The largest increases were in the commercial and industrial sectors both
up 6%. Residential sales of electricity were up 4% in 1987.

Within Florida there is a heavier reliance on petroleum in the
production of electrical energy than in the nation as a whole. Conversely,
coal utilization nationally is significantly higher than in Florida. In the
production of electrical energy for Florida's consumers in 1979, petroleum was
used for 47.4% and coal was used for 18.6% of the energy production. On a
national basis, petroleum was only used to produce 14.5% of the electricity
while coal was used to produce 46.1% (Florida Governor's Energy Office 1981).

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3.11.1.2 Other Energy Sources

Other energy sources are currently being developed in Florida.

These include direct solar, indirect solar (primarily wood burning), alcohol,
crop residue, and hydropower. These sources represented only 1.8% (24
trillion Btu's) of the total energy consumption in Florida in 1987. Total
energy from direct solar (0.7 trillion Btu's), alcohol (0.2 million Btu's),
crop residues, and hydropower (2.7 trillion Btu's) is small. The remainder is
attributable to wood and municipal waste burning (21.6 trillion Btu's)

(Florida Governor's Energy office 1981).

3.11.2 Peninsular Florida

Peninsular Florida is the portion of Florida east of the Apalachicola
River. The utility industry in Peninsular Florida consists of 42 utility
systems with 17 utility systems providing nearly 100% of the electric energy
generated in the region. In 1987, the net electrical energy capacity in
peninsular Florida was 33,913 MW. In order to allow for scheduled and
unscheduled interruptions in output from one or more units, reserve margins
must be at least between 20% and 25%. Higher reserve margins are suggestive
of excess capacity.

3.11.2.1 FP&L

FP&L is an investor owned utility which services retail customers in
35 counties in southern and eastern portions of Florida. As of December 31,
1988, FP&L served a total of 2,953,621 customers. During 1988, the net energy
for load generated by FP&L was used as follows (FPSC 1981b):

User Category	% of Net Energy Used

Residential	46.5%

Commercial	36.9%

Industrial	6.4%

Street and Highway Lighting	0.5%

Sales and Resale	1.9%

Utility Use and Losses		7.5%

Total	99.7%

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Existing generating capacity and .planned additions through 1983
consist of 13 active plants comprised of the following types and numbers of
units:

Unit Type	Number of Units

Nuclear steam	4

Fossil steam	24

Solid Waste steam	2

Gas Turbines	48

Diesel	2

Combined cycle	2

Coal	2

Total	84

Fuels used to produce a total of 45,000 gigawatt hours (GWH) of
electricity in 1979 included 23.0% residual oil, 30% nuclear, 2% coal, and 21%
natural gas (FP&L 1980a). As discussed in Section 1.5, FP&L is expected to
need additional generating capacity by 1989 (FPSC 1981b).

3.11.2.2 JEA

JEA is a municipally-owned electric utility serving retail customers
in Duval County and parts of St. Johns and Clay Counties. As of December 31,
1988, JEA served a total of 278,675 customers. During 1988, the net energy
for load generated by JEA was used as follows:

User Category	% of Net Energy Uses

Residential	40.8%

Commercial	11.1%

Industrial	39.3%

Street and Highway Lighting	0.7%

Sales and Resale	2.2%

Utility Use and Losses	5.9%

Total	100.0

Existing generating capacity in the JEA system consists of four
power plants comprised of 2 coal-fired units, 11 oil-fired steam-generating
units and 9 gas turbines. In 1988, 4.5 million barrels of oil were consumed.
Total energy production from oil amounted to 2,732 GWh. JEA consumed 2.2
million tons of coal in 1988.

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3.12 HUMAN HEALTH

A number of studies on mortality have been carried out on a county-by-
county basis for the entire United States and for metropolitan areas of the
United States. In addition, analyses have been made on the effects on human
health of specific chemical elements and compounds. The results of these
studies and analyses are summarized in this baseline health section.

3.12.1	Mortality and Morbidity

The mortality data for Duval, Volusia, and Seminole Counties, State of
Florida, and the United States are presented in Table 3-14. The data indicate
that mortality rates of selected causes during 1978 in Duval County are
comparable to national rates except that deaths due to chronic obstructive
lung disease and cirrohsis of the liver are higher for Duval, Seminole, and
Volusia Counties. The chronic obstructive lung disease group includes
bronchitis, emphysema, asthma, and chronic obstructive pulmonary disease. The
four causes combined constituted the fifth leading cause of death in 1978 in
Florida and in Duval, Volusia, and Seminole Counties. This cause group is
probably more directly related to cigarette smoking and/or air pollution than
any other with the exemption of lung cancer (State of Florida 1978) . The
death rate due to heart disease and stroke for Duval County during 1978 was
lower than for Volusia and Seminole Counties and the State of Florida.

3.12.2	Lung Cancer in the Jacksonville Area

A county-by-county survey of mortality in the United States (1950-1969)
revealed that Duval County has one of the highest rates of lung cancer in the
United States. An update of the same survey for the period 1970 to 1975 also
indicated that lung cancer mortality among white males in Duval County was the
highest recorded among all metropolitan counties of the United States, and was
greater than the national average by more than 50% (Table 3-15). A study
(Blot et al. 1981) to identify reasons for the high cancer mortality in Duval
County and along the northeast coast of Florida concluded that increased risks
on the order of 40% to 50% were associated with employment in the
shipbuilding, construction, and lumber/wood industries, particularly among

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Table 3-14

Death Rates Per 100,000 Population For Selected Causes
During 1978 (National Center for Health Statistics 1978
and State of Florida Department of Health 1978)

Cause

Heart Disease
Cancer
S troke
Accidents

Chronic Obstructive
Lung Disease

Influenza

Cirrohsis of Liver

Arterioscleros is

Diabetes

Suicide

Homicide

Prenatal Condition
All Causes

Duval Volusia/Seminole
County 	Counties

376.0	550.8

175.4	239.1

64.6	110.5

40.1	44.6

28.7	31.4

23.2	27.9

22.8	16.5
8.4	11.7

12.4	16.9

14.6	18.0

13.6	9.6

11.0	5.

840.0	1,075.0

Florida
530.4
241.3
99 .1
47 . 8

32.4
27.1

18.5
13 .4
17 . 2
17.1
11.4

7.6

U.S.A.
334.3
181.9
80.5
48 .4

23.1

26.7

13.8
13 . 3
15 . 5
12.5

9.4
10.1

1,103.7 883.4

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Ranking

1

2

3

4

5

6

7

8

9

10

Table 3-15

Morality Rates For Lung Cancer (listing of the 10 metropolitan
counties (1) in the U.S.A. with the highest age-adjusted rates
among white males. 1970-75 (2) (3))

County

Duval, F1.

St. Louis City, Mo.
Baltimore City, Md.
Chesapeake, Va.(4)
Orleans, La.

Mobile, Al.

Jefferson, Ky.

James City, Va. (5)
Chesterfield, Va. (6)
Marion, In.

Mortality Rate
(deaths/vr/10)

93.2

90.9

88.4

87.2
86.1
83.8
82.8
80.4

79.3
77.6

(1)	Includes all counties with at least 500,000 person-years of
observation among white males during 1970-75

(2)	Deaths for 1972 are excluded since not all were ascertained for this year

(3)	Source, Blot et. al. 1981

(4)	Includes the independent cities of Norfolk and Portsmouth

(5)	Includes the independent city of Newport News

(6)	Includes the independent city of Richmond

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workers with reported exposures to asbestos or wool dust. Excess risks were
also linked to fishing and forestry occupations, although the number of cases
involved was small. It should be noted that although Duval County leads the
nation in lung cancer incidence, the overall cancer rate is lower than Volusia
and Seminole Counties and the nation.

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CHAPTER 4

ENVIRONMENTAL CONSEQUENCES
OF THE ALTERNATIVES AND THE
PROPOSED PROJECT

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4.0 ENVIRONMENTAL CONSEQUENCES OF THE ALTERNATIVES AND THE PROPOSED PROJECT

This chapter summarizes the potential impacts of the No Action
Alternative and the proposed CBCP on the natural and man-made environment.
Section 4.1 defines the criteria used to analyze the impacts of all
alternatives and summarizes the criteria applied to each resource area. The
remaining sections summarize potential impacts for each resource area.

4.1 CRITERIA FOR THE EVALUATION OF IMPACTS

This section describes the criteria and general approach used to evaluate
the potential impacts of the proposed CBCP and the alternatives on the natural
and man-made environment. The potential impacts of all alternatives are
discussed in Sections 4.2 through 4.13 on a resource by resource basis.

The potential impacts of the CBCP are analyzed in detail using
information presented by the applicant and large amounts of information and
other analyses gathered and performed during the course of the preparation of
the SAR/EIS including the SAR/EIS performed for the JEA/SJRPP. The large
amount of information about the site and details of the proposed project
allowed a detailed, relatively quantitative assessment of impacts of the CBCP
including estimates of potential changes in the concentration of air and water
pollutants in the environment based on modeling. Using this approach, impacts
were estimated by comparing the potential changes in the air quality, water
quality, and other resource categories to applicable governmental standards.
Due to limitations on the amount of information that could be reasonably
gathered, however, this approach could not be used to identify impacts of all
possible alternatives. Instead, the' relative impacts of the alternatives were
identified by comparing their resource requirements and general waste
generation characteristics to provide indicators of potential harmful effects
on each resource category. The general types of criteria used in this
analysis are identified in Table 4-1 and their impact is explained in each of
the impact analysis sections.

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Table 4-1

Criteria For Estimating Potential Impacts On Resources

Resource Category

Criteria Employed

Air Resources

Surface Water Resources

Earth Resources

Biological Resources

Net change in emissions of SO2,
NOx, CO, HC, and particulates.

Net change in discharge of
chlorine, heat, trace metals,
oil and grease.

Net changes in total amounts of

groundwater used.

Net changes in total amount of

solid waste generated.

Changes in topography.

Net change in landfill area.

Number of acres of habitat
required for plant sites and
solid waste disposal areas.
Net changes in air emissions
and wastewater discharges.
Potential occurrence of rare,
threatened, or endangered
species.

Potential occurrence of
wetlands.

Sound Quality

Predicted increases in
equipment noise levels.
Predicted traffic noise levels,

Cultural Resources

Potential for occurrence of
archaeological, historic, or
cultural resources based upon
criteria of effect defined in
36 CFR 800.

Socioeconomic Conditions

Changes in influx of population
in relation to housing
availability and capacity of
community services.

Changes in employment (number
of permanent and temporary
j obs)

Amount of property tax paid by
the utilities and employees.
Amount of State educational
aid.

Service demands

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Table 4-1.

Criteria For Estimating Potential Impacts On Resources

(con't)

Land Use, Recreation and
Aes thetics

Degree of changes of existing

land use patterns

Changes in zoning required.

Consistency with comprehensive

land use plans.

Total land required.

Changes in recreational uses.

Changes in aesthetic

environment.

Transportation

Changes in coal train traffic.
Changes in amount of highway
traffic.

Changes in barge traffic.

Human Health

Net changes in air emissions
of criteria pollutants.

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In order Co understand the use of the criteria in the assessment of
impacts, it is necessary to understand several basic assumptions and
underlying methodologies. The basic alternatives to the CBCP involve
maintaining the status quo at the existing pulp mill, constructing new power
generation sources at the pulp mill, or purchasing power from another source.
It is difficult to ascribe alternatives to cogeneration sites because of the
limited industrial plants that require steam as well as electric power and who
have sufficient space to allow construction of cogeneration facilities. The
CBCP site is a viable location for a cogeneration facility in that it is next
to a customer (the SK paper mill) that can economically use the process steam
and has a large area available for industrial use. The CBCP will allow the
customer to modernize their facilities and reduce adverse environmental
impacts.

4.2 AIR QUALITY IMPACTS

This section considers the potential air impacts due to the construction
and operation of the CBCP and the alternatives. Included are discussions of
impacts of construction-related emissions, uncontrolled operation emissions,
and controlled operation emissions.

4.2.1 Construction-Related Impacts

4.2.1.1 CBCP

Emissions of air pollutants associated with the construction of a power
generating station result from clearing and grubbing, excavation, material
haulage and handling, and open burning. These activities are common to most
major construction projects. The CBCP and its alternatives, with the
exception of the No Action Alternative and the Purchase Power Alternative, are
therefore assumed to have similar construction-related emissions. Because air
emissions from construction activities are difficult to quantify and vary
significantly depending on the control measures implemented, no attempt has
been made to quantify these emissions. The production of actual emissions is
not critical since control measures for construction-related air emissions
have been shown to be highly effective.

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The primary air pollutant emitted during each phase of construction is
fugitive dust. Control of fugitive dust is primarily accomplished by watering
and soil stabilization. Stabilization includes paving or laying down a
surface (such as rock or shell) which will reduce the opportunity for
particles to become airborne. Other measures for fugitive dust control
include careful operation of on-site equipment, reduction of vehicle speeds on
unpaved areas, and rapid revegetation of cleared areas after construction.

Open burning is another source of air emissions during construction.
Typical emissions from burning activities include particulate matter, carbon
monoxide, hydrocarbons, sulfur oxides, and nitrogen oxides. The quantity of
these emissions depends largely on the amount and moisture content of the
material burned. There are no specific control measures for open burning,
although to reduce impacts, burning should be conducted during periods of good
atmospheric dispersion.

Exhausts of heavy machinery and truck traffic also are a source of air
pollutants, consisting mainly of carbon monoxide, hydrocarbons, nitrogen
oxides, sulfur oxides, and particulate matter. These emissions would be minor
due to the small number of pieces of equipment and their wide distribution
over the project site.

Construction-related air quality impacts are expected to be minimal and
of short duration if standard mitigative measures are implemented. Fugitive
dust production should be minimized through the use of watering, stabilization,
good equipment operational practices, and rapid revegetation of cleared areas.
In addition, fugitive emissions from construction activities generally consist
of large particles which rapidly settle rather than remain suspended for long
distances. This rapid setting will keep fugitive dust impacts restricted to
the project site in most instances.

Only minor short-term air quality impacts are expected to result from
burning since these operations will be conducted only during periods of good
.atmospheric dispersion. Burning should be conducted in compliance with local
and State regulations (Section 5.2 outlines appropriate mitigative measures),

4-5

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however, because of the mitigative measures which will be employed, it is not
expected that vehicular emissions, fugitive dust, or smoke from burning
operations will present any significant air quality problems.

The relative level of construction-related emissions can be correlated
with the total amount of land disturbed and the length of time that
construction takes place.

4.2.1.2 Alternatives

Alternative 1 - Purchase of Power, assumes that no additional
transmission lines would be constructed, therefore local air quality impacts
from construction activities would be negligible.

Alternative 2 - Residential Solar Water Heaters, involves the
installation of individual residential units over a period of nine years
(81,062 units/year). Since installation would occur over a wide area over a
nine year period, air quality impacts from construction activities would be
negligible. The power plant alternatives (Alternatives 3, 4, and 5) would
impact air quality by emitting fugitive dust from excavation, grading, and
traffic. Open burning would emit particulate matter, CO, hydrocarbons, S0X
and N0X. Traffic at and to and from the construction site would also add CO
and particulate pollutants to the air.

The No Action Alternative would have no impact.

4.2.2 Operational Impacts

4.2.2.1 CBCP

4.2.2.1.1 Emissions Generated

Pursuant to FAC 17-2, and 40 CFR 52.21, the CBCP units 1 and 2 are
subject to a review for the Prevention of Significant Deterioration (PSD) of
air quality. The CAAA of 1977 prescribe incremental limitations on the air
quality impacts of a new source.

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The proposed CBCP will emit seven pollutants in PSD-significant
amounts. These includes criteria pollutants CO, NOx, and Pb and non-criteria
pollutants Be, Hg, F1, and H2SO4 mist.

The FDER has reviewed the PSD analysis submitted by AES-CB and has
found that the cogeneration facility would not violate State PSD regulations
as contained in FAC 17-204. Additionally, the Preliminary Determination for
the CBCP was completed in December of 1989. Federal regulations on PSD (40
CFR 52.21) require the following air quality impacts to be addressed:

o	National Ambient Air Quality Standards (NAAQS)

o	PSD increment impact

o	Visibility, soils and vegetation impacts

o	Impacts due to growth caused by the proposed source

o	"Good Engineering Practice "(GEP) Stack height

o	Best Available Control Technology (BACT)

o	Class I area impacts

After their review, FDER has made a preliminary determination that
the construction can be approved provided certain conditions are met. A
discussion of the modeling methodology and required analyses can be found in
Appendix L.

The predicted impact of the CBCP on the Okefenokee Wilderness area
(PSD Class I area) increments is presented as follows:

Pollutant

Increment Particulate	S02

Annual 20%	50%

24 Hour 10%	80%

3 Hour N/A	72%

It appears that the CBCP would not violate the	Class I PSD
increments in the Okefenokee Wilderness.

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The percent consumption of the	applicable Class II PSD increments

caused by the CBCP and other new sources	are as follows:

	Pollutant	

Increment	Particulate

Annual	12%

24 Hour	46%

3 Hour	N/A

S02
12%
46%
65%

The CBCP should not violate the increments or cause significant
deterioration in the Jacksonville area.

Table 4-2 lists the significant and net emission rates for the
entire industrial site and Table 4-3 lists the stack parameters and emission
rates for each proposed source of the CBCP and for the existing paper mill
sources. Carbon monoxide and lead were modeled using the maximum emissions
for the facility alone. The NO2 modeling was based on the net emission change
(proposed minus existing) using an emission rate of 0.36 lb/MBtu which is
higher than the revised proposed rate of 0.29/MBtu.

The predicted maximum air quality impacts of the proposed CBCP for
those pollutants subject to PSD review are listed in Table 4-4. Sulfuric acid
mist is not listed because there is no de minimus level for this pollutant.

Given existing air quality in the area of the proposed facility,
emissions from the CBCP are not expected to cause or contribute to a violation
of an applicable AAQS. The results of the AAQS analysis are contained in
Table 4-5.

Of the pollutants subject to review, only the criteria pollutants
CO, NOx, and Pb have an AAQS. Dispersion modeling was performed as detailed
in Appendix L for the proposed CBCP. The results indicate that, except for
Pb, the maximum impacts of these pollutants were less than the significant
impact levels defined in Rule 17-2.100 (170), FAC. As such, no modeling of
other sources was necessary for CO and NOx. For Pb, there is no significant
impact defined in the rule. The maximum 24-hour Pb concentration was used as

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a conservative estimate of the quarterly concentration. When combined with
the background concentration of 0.3 ug/m3 (the highest quarterly average
between 1986 and 1987 in Duval County), this results in a total concentration
of 0.43 ug/m3 which is well below the Pb AAQS. Therefore, no additional
modeling for Pb was required.

The total impact on ambient air is obtained by adding a "background"
concentration to the maximum modeled concentration. This "background"
concentration takes into account all sources of a particular pollutant that
are not explicitly modeled. These "background" concentrations were obtained
from Department approved monitors near the CBCP site for 1986 (1985 for NOx).

4.2.2.1.2	Impacts on Soils and Vegetation

The maximum ground-level concentrations predicted to occur for the
criteria pollutants as a result of the proposed CBCP and a background
concentration will be at or below all applicable AAQS including the national
secondary standards developed to protect public welfare-related values. As
such, these pollutants are not expected to have a harmful impact on soils and
vegetation.

4.2.2.1.3	Impacts on Visibility

The proposed CBCP may have an impact on visibility in the area.
Visibility is defined as the greatest distance at which it is possible to see
and identify with the unaided eye a prominent dark object against the sky at
the horizon in the daytime or a known unfocused moderately intense light
source at night. Visibility is diminished by four major processes: light
scattering by gas molecules, light scattering by particles, light absorption
by gases not naturally occurring in the atmosphere, and light absorption by
particles. Coal-fired power plants affect visibility through the three major
combustion related pollutants: particulates, sulfur dioxide, and nitrogen
dioxide. Visibility is decreased by particulates primarily through light
scattering due to conversion of gaseous nitrogen dioxide to particulate
nitrites; and by sulfur dioxide when it converts to particulate sulfates.

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Table 4-2

Significant And Net Emission Rates (Tons Per Year) (1)

Significant	Emission	Existing	Proposed

Emission	Basis	Seminole Kraft	Maximun	Net	Applicable

Pol lutant	Rates	lb/MBtu(5)	Power Boilers	Emissions(2) Emissions Pollutant

Carbon Monoxide (CO) 100.0	0.19	606	2,470	1864	Yes

Nitrogen Oxides (NOx) 40.0	0.29	1,201	3,774	2573	Yes

Sulfur Dioxide (SOj) 40.0	0.60(3)	--	7,796	--	No

0.31(4)	4,472	4,029	-384	No

Particulate Matter (TSP) 25.0	0.02	325	268	-57	No

Particulate Matter (PM'jg) 15.0	0.02	254	265	11	No

Ozone, Volatile Organic 40.0	0.016	200	208	8	No
Compounds (NOC)

Lead (Pb) 0.6	0.007	--	91	91	Yes

Asbestos 0.007	--	--	--	<0.007	No

Beryliun (Be) 0.0004	0.00011	--	2	2	Yes

Mercury (Hg) 0.1	0.00026	--	3	3	Yes

Vinylchloride 1.0	--	--	--	<1	No

Fluorides (Fl) 3.0	0.086	--	1,122	1,222	Yes

Sulfuric Acid Mist (HjSO/;) 7.0	0.024	--	308	308	Yes

Total Reduced Sulfur (TRS) 10.0	(Negligble)	--	--	--	No

(1)	Assumes coal within 3.3% sulfur content and 18.0% ash content and a mini'muii heating value of 11,000
BTU/lb. At 93% capacity the cogeneration plant will consune .93 x 145 = 135 T/hr of coal.

(2)	Assunes a 100% capacity factor for the modified paper mill (kraft recovery boiler, smelt dissolving tank,
limestone dryers, and the multiple effects evaporator) and a 93% capacity factor for the cogeneration
plant. Also operations will continue 24 hr/days 365 days a year.

(3)	3 hour average

(4)	12 month rolling average

(5)	Cogeneration plant CFB only

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Table 4-3
Stack Parameters and Emission Rates

Stack
Hgt.

	Source		(m)

Proposed Sources

CFB Boiler	129.5

Limestone Dryer	9.1

Existing Composite
Source Data

Power Boilers	32.3

Bark Boilers	41.5

Exit	Exit	Stack

Temp.	Vel.	Dia. Emission Rates (g/sl

(K)	fm/s)	(m)	NOx	CO	Pb

403
355

33.22
21. 34

4.27
1.04

145

0.6

76.4 2.8
0.1

433
329

20.12
13.72

1.83

2 .44

23.2
11. 3

1.7
15 . 7

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Table 4-4

Maximum Air Quality Impacts Versus the de minimus Ambient

Levels

Pollutant Averaging Time

Predicted Impact
	(ug/m3)

De minimus Ambient
Impact Level (ug/m3)

CO (8-hour)
NC>2 (Annual)
SO2 (24-hour)
Pb (3-month)
Be (24-hour)
Hg (24-hour)
F1 (24-hour)

25.0
<0
<0
0.13 (1)
0.0017
0.004
1.375

575
14
13
0.1

0.0005

0.25

0.25

(1) The Pb impact is based on a 24-hour modeling value and, therefore, the
3-month Pb average is expected to be significantly less than this value.

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Table 4-5

Comparison Of Total Impacts With The AAQS

Maximum

Predicted
Pollutant and	Impact

Averaging Time	(ug/m^)

CO (1-hour)	94.10

CO (8-hour)	25.00

NO2 (Annual)(1)	3.80

Pb (3-month)	0.13

Maximum

Existing	Total	Florida

Background	Impact	AAQS

(ug/m3)	(ug/m^)	(ug/m^)

13.0	107.10	40000.0

6.0	31.00	10000.0

29.0	32.80	60.0

0.3	0.43	1.5

(1) Modeled at 0.36 lb/MBtu. Revised emission basis = 0.29 lb/MBtu.

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The frequency distribution of the visibility observed at the
Jacksonville Imeson Airport over a five-year period is summarized in the
application. The average quarterly background visibility at Jacksonville
Airport is seldom greater than twelve miles or less than two miles.

Visibility conditions greater than or equal to those measured at Jacksonville
can be expected at St. Augustine (70 km southeast) and the Okefenokee
Wilderness (PSD Class I area) (60-70 km northwest). Equations can be used to
calculate background conditions and the impacts of SO4, TSP, and visibility at
the Okefenokee (PSD Wilderness Class I area) and the St. Augustine historical
area. For purposes of this simplified analysis, it was necessary to assume
that SO4 and TSP are the only pollutants contributing to visibility reduction.
It was also assumed that the background visibility is twelve miles. The
calculated new visibility due to the CBCP was 11.7 miles.

This corresponds to a reduction of approximately two percent
(2%) in the visual range at the Okefenokee Wilderness Class I area during
worst-case conditions therefore it was concluded that the emissions from the
CBCP will not significantly alter the visibility in this area.

4.2.2.1.4 Nonattainment Areas Impacts

The extent of the contribution of the proposed CBCP to the formation
of ozone and, therefore, its' impact on the Jacksonville ozone nonattainment
areas cannot be estimated through modelling. However, because of the plant's
low emission levels of oxidants and hydrocarbons (the primary precursors of
ozone), it was assumed by AES-CB that the impacts of the proposed CBCP on
ozone concentrations in the Jacksonville area will not be significant.

The impact of the CBCP on the Jacksonville particulate nonattainment
area was estimated through modelling and compared with the EPA "significance
levels" which are one ug/m^ for an annual average and five ug/rn-^ for a 24-hour
average. The TSP nonattainment area basically covers the central downtown
area and is at its' closest point ten kilometers from the proposed CBCP.

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The annual average impact was calculated using the total TSP
emissions from the operation of the proposed plant including fugitive dust
emissions from coal handling, waste disposal and cooling towers. The results
of the analysis indicate that the annual average TSP impact on the
nonattainment area would be less than one ug/m^, the EPA significance level.
The maximum 24-hour TSP impact would be four ug/m^, which is less than the
five ug/m3 EPA significance level.

It, therefore, appears that the proposed CBCP will not have a
significant adverse effect on the downtown Jacksonville area.

4.2.2.1.5	Growth-Related Air Quality Impacts

The proposed CBCP is not expected to significantly change
employment, population, housing or commercial/industrial development in the
area to the extent that an air quality impact will result.

4.2.2.1.6	GEP Stack Height Determination

PSD regulations state that the degree of emission limitation
required for control of air pollutants shall not be affected by that portion
of any stack height which exceeds good engineering practice (GEP) or by any
other dispersion technique. The determination of the GEP stack height for the
CBCP was based on EPA regulations (40 CFR Part 51 Stack Height Regulation,
Nov. 9, 1984).

Good Engineering Practice (GEP) stack height means the greater of:
1) 65 meters or 2) the maximum nearby building height plus 1.5 times the
building height or width, whichever is less. The GEP stack height
determination is dependent on the distance and orientation to the various
buildings near the stack because the projected building width can change.

The applicant calculated the GEP heights for each proposed source
based on the dimension of nearby buildings. The GEP height of 129.5m was used
in the modelling for the CFB boiler. The proposed stack heights for the smelt
dissolving tanks is 73.1m, which is less than the calculated GEP height of

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129.5m The stacks for the limestone dryers and the lime kilns are below the
GEP limit of 65m. Each of the stacks that had proposed heights less than
their GEP limits were subjected to modelling downwash routines.

4.2.2.1.7 Best Available Control Technology (BACT)

The CBCP is to consist of three coal/bark fired CFB boilers, coal
handling equipment and limestone dryers. The CFB boilers, rated at 3,189
MMBtu, are to burn fuel made up of approximately 96 percent coal and 4 percent
bark.

Rule 17-2.500(2)(f)(3) of the FAC requires a BACT review for all
regulated pollutants emitted in an amount equal to or greater than the
significant emission rates listed in Table 4-2. The NOx emissions from the
smelt dissolving tank and the multiple effect evaporators are negligible and
were not considered as part of the BACT analysis. The emissions of heavy
metals, H2SO4, VOC's, and fluorides from the limestone dryers are also
negligible compared to that emitted from the CFB boiler and were not
considered in the BACT analysis for the CBCP. Details of the BACT
Determination procedure and analysis are provided in Appendix L. Generally
the air pollutant emissions from cogeneration facilities can be grouped into
categories based on what control equipment and techniques that are available
to control emissions from the facilities. The emissions are classified as
follows:

o Combustion Products (Particulates and Heavy Metals).

Controlled generally by particulate control devices.

0 Products of Incomplete Combustion (CO, VOC, Toxic Organic

Compounds). Control is largely achieved by proper combustion
techniques.

o Acid Gases (SOx, NOx, HC1, Fl). Controlled generally by
gaseous control devices.

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A review of the impacts associated with the proposed CBCP and the
recovery boiler installation indicates that there will be a reduction in the
maximum annual impacts. This reduction in the impacts will be attributed to
the replacement of three old power boilers and there old recovery boilers
which are now exhibiting higher impacts than what will be expected from the
CBCP.

The FDER has determined that the levels of control proposed by the
applicant for the CFB cogeneration facility represents BACT in most cases.
The review indicates that the level of particulate control clearly is
justified as BACT for particulate matter, PM^q- anc* other heavy metals. In
addition, the levels of control proposed for the coal handling facilities, and
for products of incomplete combustion is also representative of BACT.

A review of the proposed control for SO2 indicates that the inherent
removal efficiency provided by the CFB boiler represents BACT. The analyses
of alternative control technologies indicates that both the cost of using wet
scrubbers and switching to a lower sulfur content coal are cost prohibitive
based on current BACT cost of control guidelines. In addition to the greater
cost of using wet scrubbing, such an alternative has the disadvantage of
having to handle and dispose of the scrubber sludge produced.

The CBCP will be located in Duval County which is classified
nonattainment for the pollutant Ozone (17-2.16(1)(c) F.A.C.). It will be
located in the area of influence of the Jacksonville particulate nonattainment
area (17-2.13(1)(b) F.A.C.); however, the plant will not significantly impact
the nonattainment area and is, therefore exempt from the requirements of
Section 17-2, 17 & 18 & 19 with respect to particulate emissions. The
facility must comply with the provisions of PSD (17-2.04 F.A.C.).

The proposed level of control for nitrogen oxides from the CBCP,
under some circumstances would not be considered representative of BACT. The
review of the costs associated with using post combustion controls indicates
that the cost per ton of using SNCR for N0X removal from a CFB boiler does
exceed the $1,000 guideline that is used for NSPS but is well below that which
has been justified as BACT for other facilities.

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In general, Che use of post-combustion NOx controls has been a
strategy which has been evaluated in every BACT review since the "top down"
BACT policy was introduced by the EPA in December 1987. In each case, the use
of post-combustion controls was rejected due to being cost prohibitive, or on
the basis that there was not sufficient operating experience for a particular
technical application to demonstrate that the specific application was proven.

For the cases in which the use of post-combustion controls was
rejected because of being cost prohibitive, the cogeneration unit was being
constructed for peaking purposes only. As this was the case, the facility in
question would be operated well below full capacity (peaking units), thereby
resulting in cost per ton figures which were well above what has been
established as justifiable for BACT.

With regard to the technology being proven, both SCR and SNCR have
had operating experience in both Japan and Europe. More recently, several
facilities in California have been permitted with SNCR. Compliance testing
has indicated that one of the facilities which is now operating (Corn
Products) has passed its compliance test. Another operating facility
(Cogeneration National) has had trouble meeting the NOx emission limitation
while also maintaining compliance with the CO and SO2 emission requirements.
This plant has continued with adjustments targeted at achieving coincidental
compliance.

Outside of California, the application of SNCR on CFBs is extremely
limited. A recent permit for the Panther Creek Partner facility (Carbon
County, Pennsylvania), however, determined that BACT for the new CFB boilers
would be SNCR to achieve a N0X limit of 0.2 lb/MMBtu (one hour average).

The applicant has stated that SNCR systems emit various amine
compounds formed by unreacted ammonia which represents a potential adverse
human health effect. Although it has been demonstrated that ammonia slip does
occur, this does not indicate that the technology has not been proven. The
use of both SCR and SNCR as representing BACT is becoming more and more
prevalent for internal combustion engines, boilers, and turbines.

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EPA's recent BACT determinations for other facilities would tend to
support incorporation of SNCR as BACT for nitrogen oxides control for the
CBCP. Another factor that would support higher than guideline treatment costs
is the location of the CBCP. The site is located in an area which is
designated as being nonattainment for ozone. Nitrogen oxides are known to be
a precursor to ozone.

According to AES, they are locked into a fixed income source due to
contracts approved by the Florida PSC; however, at this time this has not been
documented to EPA. AES claims the additional costs of SNCR would cause the
project to become financially infeasible and result in stopping the project
and such an action would be detrimental since the project as proposed will
result in overall reductions in air quality impacts.

In determining BACT, a permitting authority must take into account
such factors as energy, environmental, economic and other cost concerns.
Although the costs determined for the application of SNCR do not, in and of
themselves, appear to be clearly unreasonable, they are such that the project
would be economically infeasible. Thus, the overall environmental benefits
resulting from this project would be lost. It is also apropos in this case to
compare the proposed BACT for the AES boilers with BACT determinations made
for differing combustion technologies. For example, stoker fired boilers
without add-on controls may generally achieve a NOx limit of 0.6 lb/MMBtu.
Assuming that SNCR would achieve a 50% reduction in NOx emissions, a stoker
fired boiler could achieve a NOx limit of 0.31b/MMBtu if SNCR were employed.
Recently, a new stoker fired cogeneration facility was permitted in Virginia
(Cogentrix, Inc.) and is required to meet a N0X limit of 0.3 lb/MMBtu through
SNCR. Because of the superior design of CFBs, the BACT proposed by AES will
achieve an even greater reduction in N0X emissions than a stoker fired boiler
with SNCR.

Based on the above discussion, 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 prior to the issuance of the final EIS. This
information could include, among other things, a comparative analysis between

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Che 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.

Fugitive dust is produced by a number of sources associated with the
project. These include the coal handling system, limestone and spent
limestone handling system, and pelletized waste handling systems. Also since
fresh water cooling towers will be used, EPA has indicated that dissolved and
suspended solids in the small droplets fraction (less than 50 microns
diameter) of cooling tower drift would be considered fugitive dust in the
impact assessment. Appendix L includes descriptions of the control systems
and/or methods proposed as BACT for these fugitive dust sources.

The dissolved and suspended solids in the small droplet size
fraction of fresh water cooling tower drift is considered by EPA to contribute
to total suspended particulates. This contribution is minimized by using high
efficiency drift eliminators in the two natural draft towers (which limit
drift to approximately .005 percent of circulating water flow) and by
maintaining the cycles of concentration of the circulating water to a low
level such as a maximum of 1.5. Additionally, a drift eliminator will be
provided to mitigate the potential effects of blow-through. Upon reviewing
the preceding information, the FDER also finds that the CBCP will not
contribute to significant adverse air quality impacts.

4.2.2.1.8 Acid Rain

In recent years the increase of rainfall acidity levels across
Florida and other parts of the country has been ascribed in part to the air
emissions from coal-fired power plants. Hence the requirement for emission
controls on these plants, designed to reduce the potential acid causing
factors. Generally, SO2 and N0X are believed to be the primary anthropogenic
agents contributing to rainfall acidification. However, a great deal remains
unknown about the amount that these two gases contribute to the problem, as
well as how and where the acidification takes place.

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It should be noted that rainfall under unpolluted conditions tends
to be somewhat acidic, on the order of pH 5.6 to 5.7. This is due to the
absorption of water in the atmosphere. Also, neither SO2 nor N0X in and of
themselves are acidic. It appears that after a certain amount of time,
estimated to be on the order of 3 to 4 days, these gases interact with
sunlight, water vapor, ammonia, and many other chemical compounds in the
atmosphere, which converts them to sulfuric acid and nitric acid. Scientists
around the world are attempting to determine the rate of these reactions,
which catalytic aids (sunlight, water, etc.) have the most effect driving the
conversion, ways to prevent the acidic end-product from affecting the
environment, where the end product eventually makes it's impacts, and numerous
other questions relating to the conversion reactions. It is universally
agreed that the entire cause-effect-control relationship is very complex.

There are three issues relevant to the' licensing of the CBCP as
emission sources in relation to acidic rainfall. These are: (1) why is the
problem of concern, (2) what will be the projects contribution to the
regional, state and country wide problem, and (3) what controls are required
to mitigate the problem?

The following effects have been ascribed to above-normal acidic
rainfall. Acid rain is listed as a cause for destabilization of clay
minerals, reduction of soil cation exchange capacity, promotion of chemical
denudation of soils, and promotion of runoff. Vegetational effects tend to be
quite varied, ranging from a few cases of reported beneficial effects, to the
more prevalent harmful effects. The harmful effects include foilage damage,
alteration of responses to pathogens, symbionts and saprophytes, leaching of
essential materials from plant surfaces, and destruction of the protective
waxy leaf coatings. Impacts to wildlife are generally indirect, but
nonetheless potentially significant via habitat alteration. Effects on
aquatic ecosystems begin with changes in water quality. The water quality
changes are brought about by acidification via direct input of rainfall (or
snow melting in the northern states), indirect changes from erosion and

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previously impacted soil contributions, as well as a cascading effect wherein
the addition of acid components and soil-based catalytic materials frees up
often-times toxic metals or other wastes which which were previously
chemically bound. These problems then effect population balances of aquatic
organisms by interfering with breeding and reproduction, poisoning, or
elimination of food supplies, which frequently result in termination of
particular species within those aquatic ecosystems. These population shifts
also occur in the aquatic vegetation, further compounding the problem.

Second, the pH levels in Florida lakes, primarily those in the
northern part of the state, have been dropping, e.g., becoming more acidic,
over the past two decades. Many Florida's perched sand lakes have little or
no buffering capacity and are therefore very susceptible to acid rain.

Trends in data seem to indicate that most of the acidity is derived
from SC>2 sources in the northeastern United States. Conversion from SO2 into
sulfuric acid appears to start affecting the environment more than 50 km from
the source, and the acid is susceptible to long range transport. Florida is
subject to frequent cold fronts moving into the state in the winter months,
which are suspected of bringing in northern-based pollutants.

Florida itself has relatively few coal-fired industries at this
time, but combustion of oil and gas as well as emissions from heavy industrie
such as pulp mills and the phosphate industry make significant contributions
to SOx and NOx loadings. Normal sources of atmospheric sulfur in this state
are derived from sea-salt, a non-polluting source which tends to obscure the
acidic sulfur components. Hence, in terms of Florida's impact on other parts
of the country, this state tends to be the recipient rather than the donor.
As more coal-fired industry is utilized, this balance may begin to shift. Th
impact from a source such as the CBCP would be to contribute slightly to the
problem, but would not be registered until some distance from the plant,
perhaps 100 km or more. The degree of impact, as implied earlier, is
extremely hard to quantify. Some studies indicate that the majority of acidi
fallout impacts may occur 200-300 kilometers from the source.

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One feature chat will mitigate some of the impact of the CBCP is the
use of stringent sulfur emission controls during operation. The CBCP will
utilize flue gas desulfurization (FGD) via a fluidized bed of limestone sulfur
emissions. N0X will be controlled by boiler design. Such control will also
help mitigate the rainfall acidification problem. The primary source of Nox
appears to be automobile emissions.

Construction of new coal fired units may have a slightly positive
effect on the acid rain problem in Florida. Data collected during the Florida
Sulur Oxides Study indicated that the conversion of SO2 to sulfuric acid forms
two to three times faster in the exhaust plume from an oil fired plant than
from a coal fired plant. Oil fired power plants in Florida do not have
emission controls for S0X or N0X in most instances. As new coal fired power
plants are built with pollution control devices, and as these new coal plants
replace the oil plants that emit greater quantities of SOx and NOx, then air
pollution levels and acidic rainfall may decrease.

4.2.2.1.9 Coal Dust from Trains

The movement of coal supply trains to the proposed CBCP from coal
mines outside the state will result in increased fugitive dust levels in areas
near the railroad tracks. These increases in fugitive dust levels will be
primarily the result of road bed dust emissions and coal dust blowing from the
exposed coal contained within each hopper car. The only other quantifiable
emissions associated with the coal trains result from the diesel locomotive
emissions, which are relatively minor.

For an impact analysis of the coal trains as they move through
Jacksonville, it was assumed that trains will travel 500 miles from the mines
and that there will be a maximum of one train every three days with 90 cars
per train, and a maximum of 106 tons of coal per car. An estimated one
percent of coal by weight will be lost as fugitive dust over a journey of
about 500 miles with an estimated 90 percent of the total losses escaping
during the first few hours of train transit. This implies that only 0.1
percent of the original coal weight will be dispersed as fugitive dust during
the rest of the trip, and only a small fraction of the 0.1 percent will be
dispersed in the Jacksonville area.

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The fugitive dust emissions from agitated road bed dust in the
Jacksonville area were estimated using USEPA Publication AP-42 (1979),
assuming that the road bed dust emissions are conservatively approximated by
emissions from motor vehicles traveling on unpaved roads and that each train
will travel at an average speed of ten miles per hour.

The 24-hour average TSP level in the Jacksonville area resulting
from the operation of one coal train per day (a conservative estimate) was
calculated to be 22 ug/m3 at a distance of 100 meters downwind of the railroad
tracks under light wind conditions. When added to the Jacksonville area
background level of 50 ug/m3, this total is relatively small compared to the
NAAQS secondary standard and Florida standard of 150 ug/m3. It is noteworthy
that the amount of the fugitive coal dust which was estimated to blow off the
coal cars is about half of the expected emissions resulting from agitation of
roadbed dust. This is primarily because of the very conservative method that
was employed to estimate roadbed dust emissions.

4.2.2.1.10 Trace Elements

Eighteen trace elements were selected for review on the basis of
reported high concentrations in coal, capability for volatilization during
combustion, potential for toxicity, and existence of regulatory guidelines.
Since a coal source analysis has not been provided, trace element
concentrations in coal were obtained from a report on trace elements in coal
samples from the eastern United States.

The predicted deposition rates were determined on the basis of coal
consumption, trace element concentration, and SO2 emission rates. Elements
considered to be volatile were assumed to exit the stack in an uncontrolled
manner. Those trace elements typically occurring as particulates or absorbed
on particulates were also assumed to exit in an uncontrolled state. These
assumptions were utilized due to the lack of information on the behavior of
trace elements passing through an FGD system. In addition, the use of these
assumptions introduced a degree of conservatism to the assessment.

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Studies of model power plants in most cases predicted increases in
soil trace element levels of less than 10 percent of the total endogenous
concentrations over the life of the model plant. It was concluded that uptake
by vegetation would not increase dramatically unless the forms of deposited
trace elements were considerably more available than the endogenous forms.

The estimated increases ranged from 1.5 x 10-5 to 1.2 x 10-2
percent, using average soil background concentrations. The estimated
increases over the 40 year life of the cogeneration plant, assuming that the
elements remained concentrated in the top 25 cm of soil over this period
ranged from 5.9 x 10-4 to 4.7 x 10-1. The assessment of these increases was
based on a number of worst case conditions. Under these conditions there
should not be a perceptible increase on an annual bases. Over the 40 year
cogeneration plant life, those elements exhibiting a higher percent increase
relative to the others studied included: As, B, Cd, Pb, Hg, and Mo.

The estimated soil concentration increase for As would be 1.48 x
10-2 mg per kg of soil over the 40 year plant life. Naturally occurring As
levels in soils average about 6 ppm. Soil As concentrations greater than 2
ppm, soluble form, have been shown to produce injury symptoms on alfalfa and
barley and as such no effect could be expected under worst case conditions.

The estimated soil concentration increase for B would be 2.5 x 10-2
mg per kg of soil over the 40 year plant life under worst case conditions.
Naturally occurring B concentrations range from 2-1000 ppm with the highest
levels found in saline and alkaline soils. The average value is considered to
be about 10 ppm. Using a toxicity level of 0.5-10 ppm for plants sensitive to
B as a means for comparison, no adverse effects to sensitive species such as
citrus would be expected under worst case operating conditions.

The estimated soil concentration increase for Cd would be 1.43 x
10-4 mg per kg of soil concentration over the average background level of 0.06
ppm, which is high in comparison with the other elements addressed. Toxicity
to plants is reported to occur when Cd concentration in plant tissues reaches
about 3 ppm and it is unlikely that the estimated soil concentration will be
high enough for the accumulation of 2 ppm in leaf tissue within the vicinity
of the proposed plant.

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The estimated soil increase for Pb would be 3.49 x 10-2 mg per kg of
soil over the 40 year plant life. Naturally occurring Pb concentrations in
soil averages about 10 ppm. Based on reported threshhold concentrations of 10
ppm lead in solution culture, the addition of 3.49 x 10-2 mg Pb per kg of soil
to soils containing as much as 5 ppm Pb should not result in any adverse
effects. It is thought that Pb enters the plant primarily through the leaf
surface. However, the effect of such accumulations cannot be predicted due to
the lack of information concerning the concentration of Pb in plants due to
leaf deposition.

The estimated soil increase for Hg would be 1.19 x 10-4 mg per kg of
soil. Naturally occurring Hg concentrations in soil average 0.1 ppm. Most
higher vascular plants are resistant to toxicity from high Hg concentrations
even though high concentrations are present in plant tissue. Concentrations
of 0.5-50 ppm are found to inhibit the growth of cauliflower, lettuce, potato,
and carrots. The addition of 1.19 x 10-4 mg per kg of soil is not considered
to result in any adverse effect.

The estimated soil increase for molybdenum (Mo) would be 2.73 x 10-3
mg per kg of soil over the 40 year life. Naturally occurring background
concentrations average about 2 ppm. Mo toxicity is rarely observed in the
field since most plants seem to be able to tolerate high tissue concentration.
A Mo concentration of 5 ppm in nutrient solution was found to be toxic to
clover and lettuce. It would appear to be unlikely that the contribution of
Mo from the proposed plant would result in adverse effects.

4.2.2.1.11 Fugutive Dust Impacts

Some of the predominant soils within the boundaries of the proposed
CBCP site are highly erodible and as such are considered to have a potential
for dust formation.

Various construction activities, including land clearing, open
burning, heavy machine operation, vehicle traffic, and road construction will
discharge certain amounts of pollutants into the atmosphere. The pollutant
generated in greatest quantities by site construction is suspended
particulates, also termed fugitive dust. The quantities of dust emitted by

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the sice construction vehicular traffic will be dependent on a number of
factors, including the frequency of operations, specific operations being
conducted, weather and soil conditions. A large portion of the construction
operations, such as land clearing and foundation excavation, will be
intermittent and usually of short duration.

Open burning will emit quantities of particulate matter, CO,
hydrocarbons, S0X and N0X. The burning of cleared land debris will be
conducted for short periods. These pollutant emissions will depend on the
amount and moisture content of the debris.

Exhausts of heavy machine and truck traffic will be a minor source
of air pollutants, consisting of mainly CO, hydrocarbons, N0X, S0X, and
particulate matter.

The impact of heavy construction activities and site preparation on
air quality will be short term and will be confined to the immediate vicinity
of the construction activity. This is primarily because most of the fugitive
dust created by construction traffic and earthmoving operations consists of
relatively large particulates. These large particles tend to settle quickly
rather than remaining suspended for long distances. To minimize dust: 1)
construction personnel will enter the CBCP site over prepared surfaces and
will park in a surfaced lot; 2) there are presently no plans for on-site
concrete production; 3) wetting will be employed on dust prone areas, as
needed; and 4) laydown areas will be appropriately stabilized. Frequent rain
showers will also help to reduce dust levels.

Only minor short-term air quality impacts are expected to result
from burning since these operations will be conducted only during periods of
good atmospheric dispersion. Burning will be conducted in compliance with
local and state regulations.

Since coal unloading, stacking and reclaiming operations can
contribute significant pollution problems to the nearby estuary via fallout of
airborne emissions, a strong quality assurance program should be implemented.
It will be necessary to establish NPDES monitoring stations in the vicinity of
the coal facilities at the storm water runoff, sedimentation ponds.

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Because of the mitigative measures which will be employed, it is not
expected that vehicular emissions, fugitive dust or smoke from burning
operations will present any significant air quality problems.

4.2.2.1.12 Global Climate Change

The composition of the earth's atmosphere is changing due to energy
and material production and development patterns. Concentrations of
greenhouse gases, primarily carbon dioxide, but also, methane, CFC's nitrous
oxides, a variety of low-volume gases, are increasing in the lower atmosphere.
These green house gases collectively function to retain heat energy,
effectively warming the earth's surface.

One option for off-setting increasing concentrations of carbon
dioxide in the atmosphere is through reforestation; however, there are no
regulations requiring such a program. Mr. Dennis Bakke, President and
co-founder of AES, Inc. testified before the State of Florida Division of
Administrative Hearings (before the Honorable Robert T. Benton, II, Hearing
Officer, on February 5-7, and February 20 and 21, 1990) that AES has set aside
money as part of the CBCP to plant trees in order to mitigate CO2 effects.

4.2.2.2 Alternatives

Alternative 2 - Residential Solar Water Heaters and the No Action
Alternative would have no operation-related air quality impacts. Alternative
1 - Purchase Power would have no local inpacts. Air quality impacts at the
source of power generation could, however, be very significant not only for
the local area but also from a global perspective.

Alternative 3 - Combustion Turbine Power Plant and Alternative 4 -
Combined Cycle Power Plant use gasified coal which can be washed and cleaned
to remove SO2 and particulates prior to combustion. N0X could be controlled
during combustion by optimizing the temperature. Significant levels of CO2
would be emitted and would require control.

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Alternative 5 - Conventional Coal-Fired Power Plant has the highest
potential air quality impact. Major emissions include SO2, N0X, CO, and
particulates. All emissions would require extensive post-combustion control
mechanisms.

4.2.3 Comparison of Impacts

All power plant alternatives (Alternatives 3, 4, and 5) and CBCP
would impact air quality to varying degrees. The new technologies of
coal-gasification and CFB systems help to mitigate the air quality impacts,
particularly SO2 emissions, of the respective Alternatives 3 and 4 and CBCP,
N0X emissions would be controlled by all power plants by optimizing combustion
temperature, but this technique requires trade-offs between control of N0X and
SO2 emissions. Post-combustion controls would still be required for
particulates and CO/CO2. The Convention Coal-Fired Power Plant, Alternative
5, would have the most significant air quality impacts and subsequently would
require extensive post-combustion control mechanisms. All power plant
alternatives, including CBCP, should consider the use of low sulfur coal to
deter the high levels of SO2 emissions generated by fossil fuel power plants.

Alternative 2 and the No Action Alternative are expected to have no
air quality impacts. Alternative 1, Purchase Power has no local impact but
could have significant impacts at the source of power generation.

4.3 SURFACE WATER RESOURCES

The potential impacts of the proposed CBCP and the alternatives on
surface water resources are summarized in this section. The OSN referenced in
this section for the various discharges refers to the NPDES outfall serial
number. These discharges are summarized in Table 3-3 of the previous chapter.

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4.3.1 Construction-Related Impacts

4.3.1.1 CBCP

The construction of the CBCP is expected to have no appreciable
impact on any surface waters. There are no bodies of water on the plant
construction site. The area is presently a storage area for lime mud from the
SK paper mill, with very sparse vegetation. Approximately 35 acres of land
west of the SK paper mill will be cleared, grubbed or filled. Approximately
10 acres within this area will be covered by coal, ash and limestone storage
and handling facilities. A silt fence will be installed along the western
perimeter of the site to prevent the deposition of silt in the Broward River
as a result of soil erosion during construction (refer to Appendix I, E&S
Plan).

The Storage Areas Runoff Retention Basin (OSN 008) , will be built
early during construction to serve as a construction runoff retention pond. A
system of temporary construction ditches and piping will direct the stormwater
runoff to the pond. The pond will initially be used for construction runoff
until the Yard Area Runoff Pond (OSN 003) is completed (late in the
construction phase). Subsequent to completion of the Yard Area Runoff Pond,
the Storage Areas Runoff Retention Basin will be taken out of service, runoff
will be routed to the Yard Area Runoff Pond and the basin will be lined prior
to receipt of coal. At that time basin effluent will be rerouted to the SK
IWTS. Therefore, no increase in runoff to the Broward River is expected, as a
result of construction activities.

During construction, temporary sedimentation ponds will be located
southwest of the railroad spur. All runoff waters generated within the
general boundaries of the rail loop during construction will be directed to
these ponds. This runoff is expected to contain little chemical
contamination, but will contain suspended solids from soil erosion as well as
BOD and nutrients from runoff.

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Runoff from areas of the site not disturbed by construction
activities will be directed to the natural drainage systems within the area.
Runoff from areas of the site disturbed by construction activities or plant
operations will be collected in a ditch system and/or catchbasin and
underground piping system and directed to ponds as described in the following
paragraphs. Drainage systems will be designed for gravity flow wherever site
conditions allow.

At present, surface runoff from site areas north of the SK paper
mill dewatering building (OSN 005) drains to the lime settling ponds located
west of the rail spurs. The supernatent from the final (northernmost) pond is
pumped into the SK paper mill sewage collection system. After being routed
through the existing clarifier and receiving biological treatment, the runoff
is discharged at the outfall structure (OSN 001) located in the St. Johns
River south of the site.

The site area between the dewatering building and the clarifier
would naturally drain to the Broward River; however, SK has constructed berms
along the river to provide containment for potential oil spills. Rainfall on
this area collects in localized depressions and eventually percolates to the
groundwater table.

Offsite runoff will not be collected in the onsite drainage system.
Swales will be provided to direct runoff which originates in offsite,
upgradient areas around the site perimeter and into existing drainage
patterns. These swales will be designed to preserve the existing drainage
conditions and water quality to the maximum extent possible.

During plant construction, the peak manpower is expected to be
approximately 990 people. Of this number, approximately 274 people are
expected to use portable, self-contained toilet facilities. Wastes from the
portable facilities will be disposed of off-site by licensed contractors. The
remainder of the work force is expected to use temporary and permanent toilet
facilities. Wastewater from these facilities will be collected by the
existing SK sanitary system which conveys wastewater to the SK IWTS before
discharge to the St. Johns River (OSN 001),

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Pre-operational boiler and condensate system metal cleaning wastes
will be treated on-site. The waste cleaning solutions, flush waters, and
associated debris will be piped to the retention basin for the neutralization
and precipitation of iron oxides and other heavy metals. The supernatant will
then be treated in the SK IWTS. The effluent will be discharged to the St.
Johns River via the SK discharge system (OSN 001).

4.3.1.2 Alternatives

The No Action Alternative and Alternative 2, Residential Solar Water
Heaters are expected to have no impacts. Alternative 1, Purchase Power is
expected to have no local impact. The power plant alternatives will impact
surface waters during construction similar to CBCP. Potential pollution of
waters could be caused-by sediment-laden storm runoff discharges and
dewatering wastewaters. Proper mitigative measures could lessen or eliminate
these impacts.

4.3.2 Operation-Related Impacts

4.3.2.1 CBCP

The primary source of water for CBCP is to be groundwater from the
Floridan Aquifer. The discharges from cooling tower blowdown (OSN 002) and
the Yard Area Runoff Pond (OSN 003) will be through the SK paper mills
discharge pipe (OSN 001) to the St. Johns River. Primary concerns with
respect to surface water quality are discharges of arsenic, chromium, heat,
copper, iron, mercury, silver, oil and grease, cadmium, aluminum, lead, ,zinc,
pH, and residual chlorine.

4.3.2.1.1 Area Runoff (OSN 003 and OSN 008)

Generally, the drainage in the area of the new facility will be
directed away from the structures and routed to either of the two onsite
storage ponds as described below. The drainage along the entrance road for
the new facilities will follow the existing drainage pattern, to the south and
west. Where required, culverts will be placed under the road to allow for
these drainage patterns.

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Surface runoff from the coal, limestone, and ash storage areas
will be collected and directed into the Storage Areas Runoff Retention Basin
(OSN 008) which is located on the western portion of the site. The coal
storage pile, limestone storage pile, and the ash storage pile will occupy
approximately 3 acres, 1 acre, and 1 acre, respectively.

The Storage Areas Runoff Retention Basin will be designed to
contain the runoff resulting from a 10-year, 24-hour rainfall event for the
entire storage and associated facilities areas, and the direct precipitation
on the pond area. Runoff from precipitation exceeding the 10-year, 24-hour
event will be detained and directed to the existing outfall to be discharged
at a rate which will not exceed the peak rate of discharge from the
undeveloped site resulting from a 25-year, 24-hour storm. Flows which exceed
that resulting from the 25-year, 24-hour storm event will be discharged via an
emergency overflow chute directly into the Broward River (OSN 008).

Runoff and direct precipitation retained within the Storage
Areas Runoff Retention Basin will be directed to the SK 1WTS. Controlled
drawdown of the runoff pond to its normally empty condition will be
accomplished through a buried pressure pipeline routed to the runoff treatment
facilities.

Yard runoff will be directed to the Yard Area Runoff Pond (OSN
003) as soon as it is operational (approximately halfway through the 2-year
construction period). This sequencing will allow time for the Storage Areas
Runoff Retention Basin to be cleaned out and the synthetic liner installed
prior to the initial delivery of coal. Once the liner is in place, runoff
from storage areas will be collected and treated as discussed above.

Surface runoff from the main plant complex area and yard areas
not affected by bulk materials handling will be collected and directed to the
Yard Area Runoff Pond which will be located in the western portion of the new
facilities area. This pond will be designed to retain, without direct
discharge, the volume of stormwater associated with 0.5 inch of runoff from
tributary site areas. The Yard Area Runoff Pond will also be sized to detain

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the runoff volume resulting from the 25-year, 24-hour storm. This volume will
be discharged at a rate not to exceed the maximum rate of discharge from the
undeveloped site for the 25-year, 24-hour storm. This controlled drainage
will be accomplished through a buried pressure pipe system routed to the
existing discharge outfall. Any flows in excess of the 25-year, 24-hour storm
runoff will be discharged via an emergency overflow chute directly to the
Broward River (OSN 003).

4.3.2.1.2 Cooling Tower Blowdown (OSN 002)

Construction of CBCP will result in significant reduction in
the amount of heat discharged to the St. John River, since SK will deactivate
its steam production plant with associated once-through cooling system.
Subsequently, the dilution flow from the SK paper mill will be a main factor
in evaluating the impact of the thermal discharge from the CBCP. The
discharge from the proposed plant will be mixed with the SK paper mill's
discharge water and diluted before being discharged to the St. Johns River.
Mathematical modeling was performed to predict the average and extreme
characteristics of the thermal plumes in the St. Johns River. Under average
conditions, the extent of the plume from the combined discharge is predicted
to be less than that for the SK paper mill's discharge alone when operating in
the once-through cooling mode. The extent of the thermal plume would decrease
over baseline conditions during all months of the year. The modeling
performed for the CBCP discharge was based on the assumptions that the CBCP
discharged into the SK IWTS, and discharged to the St. Johns River (OSN 001)
with the industrial waste effluent. The proposed plan is expected to be in
compliance with present regulatory requirements for thermal discharges from
the SK IWTS POD to the St. Johns River.

The concentration of chemical and physical constituents in the
cooling tower blowdown from CBCP will be directly proportional to those in the
makeup water. Individual chemical and physical characteristics of the
blowdown were calculated by multiplying the corresponding parameter in the
makeup water by the 4.6 or less cycles of concentration estimated for the
cooling towers. The circulating water will be treated with chemicals to

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protect the system and to prevent excessive scaling and corrosion. Sulfuric
acid will be added at the cooling tower basin to reduce alkalinity and to
control the scaling tendency of the circulating water system. The estimated
maximum use of sulfuric acid will be 5,100 pounds per day based on maximum
load conditions and expected water quality. Control of sulfuric acid feed
will be as needed to maintain an acceptable pH range in the towers. Sulfuric
acid reacts with alkalinity present in the well water to produce a circulating
water in the desired pH range (7.0 to 8.0). To further inhibit scale
deposition, an organic phosphate type scale inhibitor will be automatically
fed at the cooling tower basin as a sequestering agent. The estimated maximum
use of scale inhibitor based on maximum load conditions is 152 pounds per day
as product. Scale inhibitor will be fed automatically on the basis of
blowdown flow. The sulfuric acid and organic phosphate will be stored in
tanks located in a curbed area beside the cooling towers. The curbed areas
will be routed to the existing SK paper mill waste clarifier.

To prevent biofouling of the circulating water system,
intermittent shock chlorination will be used. A chlorine solution will be fed
into the circulating pump basin through diffusers. The estimated average
usage of chlorine will be 493 pounds per day based on a feed rate of 5 mg/1
for a total period of one hour per day.

Dechlorination of the cooling tower blowdown will be practiced
to preclude discharge of total residual chlorine in excess of discharge limits
to the St. Johns River. SO2 or sodium sulfite will be fed to the blowdown for
dechlorination. The estimated use of sodium sulfite is approximately 2.3
pounds per day. If SO2 is used, the estimated usage will be approximately 1.1
pounds per day.

4.3.2.1.3 Other Plant Effluent Streams

Wastewaters from CBCP will originate from a number of sources
other than the cooling towers. These include area runoff, coal handling, ash
handling, metal cleaning, sanitary wastes, boiler blowdown, and miscellaneous
low volume wastes. Area runoff flows were addressed in Section 4.3.2.1.1.
Effluents from boiler blowdown (OSN 004) will be reused as cooling tower

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water. All effluents not suitable for reuse and not considered yard area
runoff (OSN 003) will be treated at the SK. IWTS prior to discharge to the
paper mill's oxidation pond. The SK IWTS (Section 2.2.7) will be capable of
providing treatment for metal cleaning wastes (OSN 007) , storage area runoff
(OSN 008), and low volume process wastewaters (OSN 006). In addition,
facilities will be provided for removal of oil and grease from various waste
streams.

Low volume wastewaters and metal cleaning wastewaters are
defined by 40 CFR Section 423.11 as follows:

o Low volume waste sources - include, but are not limited

to, ion exchange water treatment systems, water treatment
evaporator blowdown, laboratory and sampling streams,
boiler blowdown, floor drains, cooling tower basin
cleaning wastes and blowdown from recirulating house
service water systems.

o Metal cleaning waste - any wastewater resulting from

cleaning (with or without chemical cleaning compounds) any
metal process equipment including, but not limited to,
boiler tube cleaning, boiler fireside cleaning, and air
preheater cleaning.

o Chemical metal cleaning waste - any wastewater resulting
from the cleaning of any metal process equipment with
chemical cleaning compounds, including, but not limited
to, boiler tube cleaning (could also include boiler
fireside cleaning, air preheater cleaning, etc., if
chemical cleaning compounds are used).

o Nonchemical metal cleaning wastes - includes all "metal
cleaning wastes" which are not "chemical metal cleaning
wastes."

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Chemical characteristics of the effluent from the CBCP
wastewater treatment systems are difficult to predict since the coal and coal
waste characteristics have not been identified. The final effluent quality
will depend on the type of coal used, intensity and duration of rainfall, and
operating characteristics of the treatment process. Nevertheless, effluent
concentrations have been estimated based on conservative values reported in
the literature for waste streams resulting from similar plant operations and
average treatment levels achieved by similar processes. These are presented
as the combined concentration of all wastewater effluents at the pump sump
(Table 4-6).

The cooling tower blowdown (OSN 002) will be combined with the
main plant discharge (OSN 001) and discharged to the St. Johns River through
the SK paper mill's discharge channel. At the point of discharge to the St.
Johns River, average concentrations are projected by the applicant to comply
with Class III water quality criteria. Maximum iron concentrations may exceed
the 0.3 mg/1 water quality criteria. A variance has been requested when
ambient river conditions exceed 0.29 mg/1 which would preclude use of a mixing
zone.

4.3.2.1.4 Steam Cycle Water Treatment

The CBCP's steam cycle water will be treated with an oxygen
scavenger, such as hydrazine, for dissolved oxygen control and with an amine,
such as ammonia, for pH control. Sodium phosphate may also be fed to the
cycle. Residual phosphate will react with calcium hardness in the boiler to
form a nonadherent precipitate. The oxygen scavenger, amine, and sodium
phosphate will be stored in the Generation Building. Estimated maximum usages
are 8.6 pounds per day of hydrazine and 17.2 pounds per day of ammonia, based
on maximum load conditions. The estimated sodium phosphate usage will be
approximately 3.9 pounds per day. Boiler blowdown will be reused by routing
to the cooling towers for use as makeup.

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Table 4-6

ESTIMATED QUALITY OF CBCP DISCHARGE TO SK IWTS

Average

Constituent		Concentration

mg/1

Five Day BOD	11

COD	32

TOC	17

TSS	39

Ammonia	1.1

pH (in pH units)	7.1

Oil and Grease	10

Calcium	77

Magnesium	141

Sodium	1,441

Potassium	4.2

M-Alk as CaC03	203

Sulfate	3,264

Chloride	151

Nitrate	5.6

Fluoride	3 .0

Silica	183

Chlorine	0.00

P Total	0.06

Cyanide	0.00054

Fe	2.2

Mn	0.27

Al	1.8

Ni	0.01

Zn	0.05

Cu	0.005

Cd	0.0002

Cr	0.006

Be	0.00015

As	0.000045

Se	0.00004

Sb	0.000018

Hg	0.000037

Ba	0.02

Ag	0.0001

Pb	0.01

T1	0.000018

Maximum
Concentration
mg/1

11
83
32
58

1.1
9.0

12
81
141
1,492
4.3
210
3,264
157

6.5

3.2
190
0.02
0.07
0.0016

6.6
0.94

6.3
0.04
0.16
0.05
0.00069
0.02
0.00052
0.00015
0.00014
0.000063
0.00013
0.067
0.0004
0.027
0.000063

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4.3.2.1.5 Sanitary Wastewater Treatment

The sanitary wastewater produced by the CBCP will be routed to
the existing sanitary facilities at the SK paper mill. The annual average
expected flow of sanitary wastewater is 4,100 gpd (3 gpra) based on an average
plant staff of 75 people and an average requirement of 55 gallons per capita
per day. The average expected biological loading is 5.6 pounds of BOD5 per
day, based on 0.075 pound of BOD5 per capita per day.

4.3.2.1.6 Makeup Water Demineralization

The makeup water to the steam cycle will be demineralized using
three ion exchanger type demineralizer trains. The demineralizer system will
use sulfuric acid for cation resin regeneration and sodium hydroxide for anion
resin regeneration. The sulfuric acid and sodium hydroxide will be stored in
tanks located in or adjacent to the Water Treatment Building. The use of
these chemicals will be on an intermittal basis dependent on demineralizer
operation. Based on the maximum plant capacity and makeup requirements, the
estimated usage rate for 66 degree Baume' sulfuric acid will be 5,660 pounds
per day, and the rate of 100 percent sodium hydroxide will be 4,717 pounds per
day. The wastes from this system will be regenerant water containing
unreacted sulfuric acid and caustic plus sodium and sulfate salts of the ions
removed from the ion exchange resins during regeneration. The estimated
regenerant waste flow will average 147,000 gpd based on maximum load
conditions. These wastes will be routed to the neutralization basin for pH
adjustment and then to the existing SK waste clarifier.

4.3.2.1.7 Return Condensate Polishing

A powered resin type condensate polishing system will be used
to remove both suspended and dissolved solids from the process condensate
being returned from the SK paper mill. The wastes from this system will
consist of condensate quality water containing the spent powered resin. The
production of these wastes will be on an intermittent basis and will depend on
the quality and quantity of the condensate being returned. The estimated
wastewater flow will average 730 gpd. This wastewater, which contains high
suspended solids, is not suitable for reuse within the water system and will
be routed to the existing SK paper mill wastewater clarifier.

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4.3.2.1.8 Metal Cleaning (Chemical and Nonchemical Wastes)

Chemical Metal Cleaning

The boiler and preboiler cycle piping will be chemically
cleaned initially commissioning and also periodically during the life of the
plant. The chemicals used will not be stored onsite and will be administered
by means of a temporary system. The chemical cleaning solutions to be used
for acid and alkaline cleaning of the boiler will be somewhat dependent on the
boiler manufacturer selected. The actual cleaning solutions used must be
consistent with the boiler manufacturer's recommendations. Chemicals
typically used in boiler and preboiler cleaning include the following.

Inhibited hydrochloric acid.

Ammonia bifluoride.

Hydroxyacetic acid.

Formic acid.

Disodium phosphate.

Trisodium phosphate.

Soda ash.

Nonfoaming wetting agents.

Foam inhibitors.

Wastewaters will consist of the cleaning solutions and material
removed during the cleaning process. Since cleaning the metal piping is an
infrequent maintenance operation, it does not contribute to the liquid wastes
produced by the normal operation of the plant. However, it has very high
concentrations of dissolved heavy metals (iron may be as high as 10,000 mg/1
or more) The preoperational chemical cleaning wastes are estimated to be
approximately 180,000 gallons, with subsequent acid cleaning resulting in an
estimated additional 105,000 gallons for each cleaning operation. AES has
indicated on-site treatment facilities (portable) as well. The chemical
cleaning contractor will be required to haul offsite and properly dispose of
the wastes resulting from chemical cleaning which have metal concentrations in
excess of the requirements of 40 CFR Part 423 for new sources. Chemical
cleaning wastes that meet the requirements of 40 CFR Part 423 for new sources
will be routed to the SK IWTS, with pretreatment provided as necessary.

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Nonchemical Metal Cleaning

Nonchemical metal cleaning wastes will result from periodic
washing of the boiler firesides and air preheaters. The frequency of these
cleaning operations will be a function of the cleanliness of the equipment and
will be determined once the plant is in operation. The air preheater wash
water and the boiler fireside wash water will contain dissolved and suspended
solids in high concentrations due to ash washed from the plant components. It
is anticipated that both fireside wash water and air preheater wash water will
tend to be basic because of the injection of limestone into the fluidized bed
boiler and the resulting reaction of sulfur with the limestone to form calcium
sulfate. Because the wash waters will not be acidic, the metal content of the
wash waters will be minimal. Nonchemical cleaning wastes will be routed to a
neutralization basin for pH adjustment and then to the SK IWTS facility.

4.3.2.1.9	Miscellaneous Chemical Drains

Chemical wastewater can result from draining a chemical storage
tank, overflowing a chemical tank during a filling operation, or from
maintenance operations such as hosing down chemical storage areas. These
wastes will be routed to the neutralization basin via the chemical drains
system. Flows from the miscellaneous chemical drains will be intermittent and
will not normally contribute to the wastewater flows.

4.3.2.1.10	Neutralization Basin

A neutralization basin of approximately 150,000 gallons
capacity will be provided for treatment of chemical wastes (excluding metal
cleaning wastes) prior to their ultimate disposal. A basin of this capacity
will be sufficient to accommodate the wastewaters produced during regeneration
of the makeup demineralizer. The neutralization basin will be a reinforced
concrete basin lined with chemical resistant membrane, brick, and mortar. A
chemical waste mixer, mounted on a walkway spanning the basin, will be
provided to hasten pH adjustment of the chemical wastes. Sulfuric acid and
sodium hydroxide will be added, as required to neutralize the pH.

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4.3.2.2 Alternatives

All power plant alternatives and CBCP would impact surface water
quality in much the same way. Operation discharges would contain significant
levels of arsenic, chromium, heat, copper, iron, mercury, silver, oil and
grease, cadmium, aluminum, lead, zinc, pH, and residual chlorine.

The No-Action Alternative and Alternative 2, Residential Solar Water
Heaters, would have no surface water impacts. Alternative 1, Purchase Power
would have no local impacts.

4.3.3 Comparison of Impacts

All power plant alternatives would have impacts similar to CBCP, whereas
the other alternative would have none or negligible local impacts. The
treatment facilities and mitigative measures proposed in Section 4.3.2.1 for
CBCP could, for the most part, be employed by any of the power plant
alternatives to significantly reduce surface water impacts.

4.4 GROUNDWATER IMPACTS

4.4.1 Construction - Related Impacts

4.4.1.1 CBCP

4.4.1.1.1 Water Table Zone

Groundwater quality impacts due to construction activities will be
neglible. Studies show that, water that infiltrates the soil at the site
flows to the water table, then nearly horizontally towards the Broward River
and the St. Johns River. As stated in Section 4.3.1.1, during construction
runoff will be directed to the Storage Area Runoff Retention Basin for
discharge to surface waters. Seepage from this basin to the ground will flow
to the water table, then to the Broward River.

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4.4.1.1.2 Shallow Aquifer

Dewatering for the coal receiving structure will be required. It is
estimated that 2,000 gpm will be needed from the shallow aquifer for 6 months
during excavation and structural construction. It is expected that there will
be no effect on any off-site shallow wells.

4.4.1.1.3 Floridian Aquifer

Construction water will be withdrawn from the existing SK paper mill
wells. The additional quantity of water required for construction is not
expected to cause the SK wells to exceed permitted withdrawal rates.

4.4.1.2 Alternatives

None of the alternatives should significantly impact groundwater
resources during operations. The only exceptions would be possible
infiltration of polluted leachate from storage areas and the short-lived
impact of pumping large quantities of groundwater during dewatering efforts
for constructing the power plants of Alternatives 3, 4, and 5.

4.4.2 Operation - Related Impacts

4.4.2.1 CBCP

Any increased production from the Floridan aquifer in Duval County,
including the CBCP has the potential for inducing increased chloride
concentrations within the aquifer. As noted in the application, on a regional
basis higher chloride concentrations in the Floridan aquifer can generally be
correlated with high rates of production from the aquifer, particularly from
deeper zones (i.e., the lower part of the upper permeable zone of the Floridan
aquifer). There is correlation of higher chloride concentrations in the
Floridan aquifer with areas of higher production, such as Fernandina Beach,
the City of Jacksonville well field, and the Eastport area west of the
Seminole Kraft site.

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Within Che immediate site vicinity, chloride concentrations in
Floridan aquifer wells are generally about 40 mg/1. There are exceptions such
as a well located on Blount Island where the chloride concentration was 71
mg/1 in 1978. This well is 1051 feet deep. Increases in chloride
concentrations with time have been observed at other wells near the site (from
about 25 mg/1 in 1973 to 40 mg/1 in 1979; from 23 mg/1 in 1973 to 40 mg/1 in
1975). One such well is 1025 feet deep, while the depth of the southwestern
well is unreported.

Current plans call for using SK paper mill's	Florida aquifer

production well network consisting of seven (7) wells.	CBCP groundwater usage

for plant operation and cooling is expected to average	5.44 mgd with an
instantaneous maximum demand of 7.0 mgd.

Freshwater use in Duval County is 173.5 Mgal/day, with 158.01
Mgal/day from the Floridan Aquifer. Power generation in Duval County requires
3.09 Mgal/day. The CBCP would increase the daily requirement for power
generation to 10 Mgal/day.

Total water withdrawn from the Floridan Aquifer for power generation
within the St. Johns Water Management District was 133.72 Mgal/day in 1986.
The CBCP would increase the total withdrawn for power generation to 143.72
Mgal/day.

The increased withdrawal from the Floridan Aquifer by the CBCP will
increase the core of depression in the piezometric surface of the Floridan
aquifer in the area of the present paper mill's well field. The free flowing
production capacity of each of the seven wells is approximately 7,500 gpm.
Wells 1 & 2 are equipped with pumps; however, they are used on a standby
emergency basis. Wells 4, 5, 7, 8, and 9 are used on a rotating basis to
produce 20 mgd with a maximum 25 mgd. At maximum individual well production,
this would require utilization of two wells at 7,500 gpm and one well at 2,400
gpm.

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The CBCP's requirement of an additional withdrawal of 7 mgd (4,900
gpm) from the well field would be equivalent to three wells at a full design
withdrawal rate of 7,500 gpm per well. This assumes the paper mill is at
maximum usage and would require full capacity of Wells 7, 8, and 9. Since the
paper mill will at times use Wells 9 and 8 at full capacity, the additional
CBCP usage would be to add full capacity usage of Well 7.

The calculated radius of influence of Well 7 is approximately 800 feet at
full capacity production. SK has noted no drawdown effects from adjacent
production wells during actual pump operation at a well spacing of
approximately 1,000 feet. No wells other than the paper mill's wells are
included in a mile radius of influence of Well 7. No wells outside the paper
mills well field will therefore be affected. The additional drawdown at the
existing wells, due to the added usage of Well 7, will not affect the
production capacity of the paper mill's wells.

It should be emphasized that the maximum drawdown effect will be a very
short term effect lasting for a period of less than 24 hours.

It would appear that only limited groundwater impacts may be felt by the
homes and farms located north and west of the plant site. Due to existing
drought conditions the water pressure in artesian wells has dropped
significantly. The drawdown caused by the paper mill's production wells could
cause an additional slight reduction in artesian flow.

4.4.2.2 Alternatives

The major impact on groundwater resources during operations would be
the use of large quantities of potable water for cooling needed for the power
plants of Alternatives 3, 4, and 5 (this impact evaluation assumes the use of
mechanical draft cooling towers by the power plants). Large consumption of
potable water from the Floridan Aquifer could significantly lower the levels
in nearby residential wells and could encourage salt water intrusion.

The No-Action Alternative and Alternatives 2, Residential Solar
Water Heaters, would have no groundwater impacts. Alternative 1, Purchase
Power, would have no local impacts.

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4.4.3 Comparison of Impacts

All power plant alternatives would have impacts similar to CBCP, whereas
the other alternatives would have none or negligible local impacts.

4.5 GEOLOGICAL RESOURCES

4.5.1 Construction - Related Impacts

4.5.1.1 CBCP

Construction activities, such as clearing of the site, building
temporary or permanent roads, waste disposal and laydown areas for building
materials, are all phases of construction that will affect the site area.

Clearing the site of natural vegetation will be kept to a minimum to
minimize erosion and to reduce the negative impacts to terrestrial
communities. A relatively small buffer approximately fifty feet wide will be
placed around each of the wetland areas contiguous with the Broward River.
The natural buffer which results will serve to slightly filter any noise from
plant operations and will serve as a slight visual barrier to the plant
itself. However, the validity of using such a small buffer to protect the
adjacent wetlands and estuary remains dubious.

The SK paper mill operation has already affected much of the site.
Construction areas will be cleared and grubbed. Clearing and grubbing wastes
will be disposed of either by burning or burial. If burning is chosen as the
best approach, burning operations will be conducted in accordance with local
and state requirements. After clearing and grubbing, the construction areas
will be graded and appropriate measures will be employed to control erosion
such as seeding and grassing the lightly traveled laydown areas. Heavily
traveled construction areas and roads will be stabilized with shell or rock.
Dust from high traffic areas will be controlled with water sprinkling.

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The entrance from East Port Road during construction will be a paved
or coated surface road used primarily by construction personnel. It will
provide a route to the employee parking area which is to be located to the
east of the boiler building.

The access road from Eastport Road will be paved both	during and

after construction. During construction, this entrance will be	for material

receiving. The road will be 20 to 24 feet wide. Once the CBCP	is complete,
this access road will be rerouted and will serve as the main entrance for the
proposed plant.

The railroad spur will come off the existing SCX spur	to the paper
mill. The spur will approach the plant from the north.

Waste materials will be disposed of in accordance with applicable
rules and regulations. A number of waste materials such as scrap wood and
iron will be taken to a specified open area of the site where they will be
separated and stock piled for possible salvage. General waste materials will
be disposed of in dumpsters for collection and possible disposal at the city
landfill adjacent to the site or other suitable and approved local landfill
areas. Lime mud waste will be excavated and moved to a secured landfill on
the north of the SK paper mill property.

4.5.1.2 Alternatives

None of the alternatives are expected to have any significant impacts
on geological resources during construction.

4.5.2 Operation-Related Impacts

4.5.2.1 CBCP

Solid waste is generated from a number of sources at a power plant.
The largest quantity of solid wastes produced by the operation of CBCP is
generated by the fluidized bed system. Coal combustion ash, in the form of
fly ash, is the other major solid waste. Collectively, spent fluidized bed

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media and coal ash are referred to as "high volume solid wastes". Other
comparatively small quantities of solid wastes, generated on an infrequent
basis by the operation of the plant, include sludges from the sedimentation
ponds, retention basins, cooling towers, and wastewater treatment facilities.

Ash is the residue produced by the combustion of coal. It consists
of the unburned organic matter and the inorganic mineral constituents present
in the coal. The quantity and chemical characteristics of ash depend on the
coal, boiler operating conditions, and air pollution control devices among
others. Two types of ash are produced during combustion, fly ash and bottom
ash. Fly ash consists of the finer particles that are entrained in the flue
gas stream. Bottom ash is the coarser, heavier material that accumulates in
the fluidized bed media in the form of a loose ash or slag.

Approximately 315,000 million tons per year of bottom ash and spent
media are expected to be generated. Maximum rate of production of spent
fluidized bed media is expected to be about 56 tons/hour for all units. The
spent media will be transported to the pelletizing facility. After
pelletizing, the material will be transported to the solid waste holding area.

Fly ash will be generated at a maximum rate of about 38 tons/hour
for three units. Fly ash will be pneumatically conveyed to temporary storage
silos, before mixing with spent fluidized bed media and water to form pellets.

Compared to the high volume solid wastes, quantities of other
miscellaneous solid wastes will be insignificant. These miscellaneous solid
wastes will be disposed of in SK engineered landfill on-site section.

Periodic removal of sediments from the sedimentation pond will
generate a solid waste. Due to the number of variables involved, such as
rainfall frequency and duration, concentration of suspended solids in the
influent, etc., it is difficult to predict the quantities of sediment removed.
Frequency of sediment removal should be once per year or less. Removed solids
will consist mainly of coal dust and ash.

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Suspended solids in Che metal cleaning wastes that settle in the
retention basin will also be removed periodically. Solids will consist
primarily of ash and iron particles. Removal is expected to occur once every
three to five years.

Cooling towers are expected to be drained approximately once per
year and the accumulated solids removed. The solids will contain suspended
solids from the makeup water and particulates from the atmosphere.

Sludge from the chemical wastewater treatment facility, produced
during treatment of metal cleaning wastes, will primarily consist of calcium
carbonate and magnesium hydroxide. Quantities will depend on the influent
wastewater characteristics and length of operation of the facility. The sludge
will be removed as required.

Oil-bearing wastes from the oil-water separators will be collected
for off-site disposal or reused by licensed vendors. These wastes may also be
incinerated in the boilers along with the coal at selected times.

4.5.2.2 Alternatives

None of the alternatives are expected to have any significant
impacts on geological resources during construction.

4.5.3 Comparison of Alternatives

Impacts on geological resources are expected to be none or neglible
for all alternatives, including CBCP.

4.6 IMPACTS ON SOUND QUALITY

4.6.1 Construction - Related Impacts

4.6.1.1 CBCP

Noise impact projections were made for construction activities. The
highest noise levels will result from earthmoving activities, which will be
conducted concurrently for all units.

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Estimated construction noise levels (excluding pile driving and
steam blowout) at the nearest residence will vary throughout the course of the
construction period. The maximum daytime noise level predicted at that
residence is 65 dBA. This level will be attained only during normal working
hours for approximately 1 and 1/2 years and will be in compliance with the
Jacksonville noise control ordinance. The construction noise impact at this
location will be noticeable. However, this 65 dBA level is above EPA's
guideline of 55 dBA for protecting against outdoor activity interference.

This means that occasionally there may be some interference of outdoor
activity at this location. There should be less of an effect on indoor
activity since about a 15 dBA reduction in noise levels can be achieved by
closing windows and doors. If nighttime construction is necessary, noise
impacts are expected to be less than 60 dBA.

Two other construction activities which will have noise impacts are
pile driving and blowout of the steam lines just prior to start-up of the
plant. One pile driver operating intermittently during the first year will
produce peak impact levels of 101 dB at 50 feet as the hammer strikes the
pile. This level will be reduced to between 60 and 65 dB at the nearest
residence and will sound like a distant thumping at a frequency of several
blows per minute.

Steam blowout is the procedure whereby the steam lines in the plant
will be cleared of welding and any other debris by blowing them out with high
pressure steam prior to plant start-up. This activity will generate the
greatest noise levels, 129 dBA at 50 feet, associated with plant
construction. However, the duration is short, less than 3 minutes per blow,
and the total number of blows is estimated to be 20.

4.6.1.2 Alternatives

The power plant alternatives would generate noise during
construction. This noise would primarily be caused by pile driving and steam
blowout.

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The No-Action Alternative and Alternative 2, Residential Solar
Water Heaters, would have no sound quality impacts. Alternative 1, Purchase
Power, would have no local impacts.

4.6.2	Operation-Related Impacts

4.6.2.1	CBCP

In the SCA, AES identifies the major sources of operational noise
for CBCP. These include the Generation Building, boiler draft fan, cooling
tower, coal and limestone delivery and processing, vehicular traffic to and
from the plant, and the chemical recovery complex. Other less significant
sources include various electric motors, transformers, and fans used for dust
collection. Trains are estimated to arrive every three days. It is
anticipated that coal and limestone processing, which includes reclaim,
transfer, and crushing, will operate during daytime hours (10:00 a.m. to 7:00
p.m.) only. This will tend to minimize any impact from the project. Using a
computer model, AES predicted that operational noise impacts during worst case
conditions will be less than 65 dBA and 70 dBA at the property lines and less
than 60 dBA at the nearest residence.

4.6.2.2	Alternatives

The power plant alternatives would generate sporadic sound quality impact due
to coal train deliveries and vehicular traffic to and from the plant. Minor
power plant operation noises would be masked by traffic.

The No-Action Alternative and Alternative 2, Residential Solar
Water Heaters, would have no sound quality impacts. Alternative 1, Purchase
Power, would have no local impacts.

4.6.3	Comparism of Impacts

The only major sound quality impacts would occur during the construction
of power plants of Alternatives 3, 4, and 5, and CBCP. This impact would be
temporary and consists mainly of pile driving and steam blowoff.
Operation-related impacts for the power plant alternatives and CBCP would be
sporadic noises caused by coal deliveries by train.

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4.7 AQUATIC AND TERRESTRIAL ECOLOGY

4.7.1 Construction - Related Impacts

4.7.1.1 CBCP

4.7.1.1.1 Terrestrial Wildlife

Construction of the proposed CBCP and it's associated disposal areas
will disturb or eliminate approximately thirty acres of poor quality,
previously disturbed wildlife habitat, with the pine flatwoods being most
affected. Since the 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. Site preparation will also
destroy smaller, less mobile mammalian, reptilian, and amphibian populations
in those areas designated for development. Based upon the applicant's field
studies, these groups generally exhibited low population densities, and few
species were encountered in each taxa. However, no data were provided on how
important these animals are in relation to the ecology and the trophic
structure of various communities at the site.

No wide-spread negative impacts on ecologically sensitive areas can
be expected. Mitigative measures will be utilized to minimize adverse impacts
such as the construction of a storage area runoff pond to intercept runoffs
from site preparation and plant construction which will prevent significant
impacts resulting from increased turbidity and TSS inputs to the river
populations dependent on the marsh and river for food or cover. The ponds
will be designed to provide a 24-hour retention of runoff produced by a
10-year, 24-hour design storm and retain accumulated solids. Effluent from
the pond is to overflow a weir into the Broward River.

The construction will impact some of the resident gopher tortoise
(Gopherus polyphemus) population. 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. While the Eastern Indigo Snake (Drymarchon corais;

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Threatened) and Florida Gopher Frog (Rana aroleata aesopus; Rare) were not
encountered on the site, no studies were designed to determine whether or not
these species were, present. The Gopher Frog is a nocturnal amphibian which
emerges from it's retreat only after dark, and hence, may be more abundant
than previously indicated. Moler (1980) has noted, however, that the Indigo
snake populations are quite low in Duval County, but no data are available for
the CBCP site. Because tortoise populations have already been significantly
reduced as a result of operations which are currently underway, and because
the significance of the impacts incurred by this species due to additional
disturbances cannot be firmly predicted, it is important that maximum
protection be afforded the gopher tortoise. It may be necessary to relocate
gopher tortoise populations as well as some of the associated commensal
species.

The marshes adjacent to the site appear to be ecologically important
as feeding grounds for numerous aquatic and terrestrial species. Many wading
birds such as the Great Blue Heron (Ardea herodias), Great Egret (Casmerodius
albus), Louisiana and Night Herons (Hydranassa tricolor and Nicticoraz spp,
respectively) , and Wood Stork (Mycteria americana), which are commonly
observed in the marsh areas, are increasingly faced with widespread habitat
losses in Duval County (over 200,000 acres of marsh have already been diked or
drained along the St. John's).

4.7.1.1.2 Aquatic Life

Site preparation and plant construction activities may adversely
affect aquatic biota encountered in one on-site freshwater pond. While this
area is only a directly important habitat to those species with short life
cycles (due to the ephemeral nature of ponds), such organisms are essential
components of the terrestrial food webs. Although no commercially important,
rare, or endangered species were observed in the freshwater habitat, American
alligator (Alligator mississippiens^s) could, theoretically, be expected to
inhabit this area occasionally.

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Aquatic organisms inhabiting rivers bordering potentially be
affected by increased turbidity resulting from surface runoff. Smaller,
non-motile organisms would be expected to incur the greatest damage, and it is
not clear how the loss of this food source would affect predators in aquatic
food webs. If adequate storm water runoff controls are exercised as proposed
by the applicant, these effects could be minimized. Surface water drainage
from the site will be controlled in order to insure that drainage waters will
conform to applicable standards.

Estuarine areas adjacent to the CBCP site provide valuable feeding
and nursery grounds for numerous finfish and shellfish, some of which are
commercially important. The American Alligator (Alligator missippiensis), a
threatened species, regularly frequents the area. Marine mammals observed in
the are protected by federal, state and international law and include the West
Indian Manatee (Trichechus manatus) and common dolphin (Delphinus delphus)
Since these nearshore estuarine environments and the biota which inhabit them
would ultimately receive the brunt of the runoff wastewaters associated with
plant activities, it is crucial that extensive precautionary measures be
seriously considered and implemented. Site preparation and plant construction
are not expected to adversely affect biota encountered in the Broward River or
St. Johns River since this area is well removed from the construction
activities. Furthermore, these waters are not expected to receive storm water
or sanitary waste discharges or other effluents resulting from
construction-related activities.

4.7.1.2 Alternatives

The No-Action Alternative and Alternative 2, Residential Solar
Water Heaters would have no impacts on aquatic or terrestrial ecology.
Alternative 1, Purchase Power, would have no local impact.

Since it is assumed that the power plant alternatives (3, 4, and 5)
would be constructed at the CBCP site, the impacts would be the same for the
alternatives as those expected by CBCP. The primary concern would be for the
preservation of wildlife, particularly the gopher tortoise, during the
construction for the railway spur.

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4.7.2 Operation-Related Impacts

4.7.2.1	CBCP

4.7.2.1.1	Terrestrial Wildlife

CBCP operations in themselves should have only minimal adverse
impacts on terrestrial wildlife. The construction activities of a power
plant, which are addressed in section 4.7.1, are the primary impact activities
in that they have potential to destroy natural wildlife habitats if they
exis t.

4.7.2.1.2	Aquatic Life

The thermal effluent from CBCP will combine with the SK
discharge. At worst it could slightly raise the temperature of the combined
wastewater discharge during winter months. At best, CBCP cooling tower
blowdown could decrease the temperature of the SK wastewater discharge by
0.3°F. Adverse thermal impacts on estuarine organisms should be minimal.

The metal cleaning wastewaters conveyed to the SK IWTS for
treatment and discharge to the St. Johns River may exceed the State water
quality limits for iron. This increase of iron concentration will exacerbate
the existing pollution conditions of the river and will have an adverse impact
on aquatic life.

4.7.2.2	Alternatives

None of the alternatives should significantly impact the aquatic and
terrestrial ecology during operations. The power plant alternatives (3, 4,
and 5) would have minor impact on wildlife habitats because of additional site
development and on fish because of wastewater discharges that exacerbate
existing water quality problems in the St. Johns River.

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4.7.3 Comparison of Impacts

The only major impact would be the impact on wildlife habitat,
particularly the gopher tortoise, by the power plant alternatives (3, 4, and
5) during construction as is the case for CBCP. It is recognized that the
proposed power plant site, which is zoned for industrial use, is already
changed from its natural state due to pulp mill activities, therefore the
impact is considered minor.

4.8 IMPACTS ON CULTURAL RESOURCES

4.8.1 Construction-Related Impacts

4.8.1.1	CBCP

There are presently no areas on, nominated to, or declared eligible
for the National Register of Historic Places of the National Registry of
Natural Landmarks within the boundaries of the CBCP site, or the preferred
transmission line corridor. These same locations contain neither lands
specially designated under state programs, nor known areas valued as natural
landmarks or for their historic (excluding archaeological), scenic or cultural
significance. Subsequently, CBCP construction activities will have no known
impacts on cultural resources.

4.8.1.2	Alternatives

None of the alternatives are expected to have significant impacts on
cultural resources during construction.

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4.8.2 Operation-Related Impacts

4.8.2.1	CBCP

Since no cultural resources are known to exist within the site
boundaries (refer to section 4.8.1.1), no adverse impacts on cultural
resources are expected to occur due to operation activities. In considering
off-site cultural resources, the site facilities should not be visible from
the Fort Caroline National Monument or the Kingsley Plantation on Ft. George
Island. There does exist some potential for CBCP air emissions to contribute
to the formulation of acidic rain which has been documented to contribute to
the degradation of building facades, particularly historic buildings made of
easily corrodible materials.

4.8.2.2	Alternatives

None of the alternatives are expected to have significant impacts on
cultural resources during operations.

4.8.3 Comparison of Impacts

Impacts on cultural resources are expected to be negligible for all
alternatives and the CBCP.

4.9 SOCIOECONOMIC IMPACTS

4.9.1 Population Impacts

4.9.1.1 CBCP

The number and pattern of settlement of the immigrant construction
workers will have certain positive and negative effects on the Jacksonville
area. Immigrant workers are defined as those skilled or semi-skilled workers
who will immigrate to the Jacksonville area to work on the proposed project
and will remain in the area as long as project work is available. It is
assumed by the applicant that the secondary employment generated by the

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proposed CBCP will be filled by local employables. The only population
increase attributable to the proposed CBCP was assumed to be the immigrant
construction and operational workers and their families.

During the peak construction year of 1991, the immigrant population
would total approximately 300 persons. The greatest concentration of
immigrant population in the region during the construction phase would occur
in Duval County. During the peak construction year, most immigrants are
expected to locate in Duval County. Clay and Nassau Counties would have the
second and third most significant total population effects, respectively. The
remaining four counties in the region are projected to experience minimal
population impacts as a result of the construction phase.

4.9.1.2 Alternatives

The only alternative that may have a potential population impact is
the No Action Alternative. No Action would lower the availability of power
supply and subsequently may discourage development which in turns discourages
population growth.

4.9.2 Economic Impacts

4.9.2.1	CBCP

During the peak construction year of 1991, the proposed CBCP is
expected to generate a total of 633 new basic jobs and 1000 new non-basis
secondary jobs. The cumulative income effect of the proposed facility during
the entire construction period (1982-1987) is projected to be in excess of
$288 million.

4.9.2.2	Alternatives

The No Action Alternative may have an adverse economic impact
because the lack of available power supply may discourage development in the
area.

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The power plant alternatives (alternatives 3, 4, and 5) and the
Residential Solar Heater Alternative would have a positive impact on the
economy because not only do they provide additional power generating capacity
but they also create jobs for construction, operation, and maintenance of
facilities.

4.9.3	Community Services Impacts

4.9.3.1	CBCP

Construction activities associated with the proposed CBCP will
induce additional public costs for Duval County. The most significant of
these costs will be road repair and improvements. Due to increased traffic
during construction, the roads and major intersections in the vicinity of the
proposed CBCP may need upgrading. There will also be public costs incurred
because of the additional demand on various public services by the immigrant
work force and their families. Providing reclaimed water to the facility will
be an initial cost to the city that could be reclaimed via fees charged to
CBCP.

4.9.3.2	Alternatives

None of the alternatives are expected to have a significant impact
on community services.

4.9.4	Comparison of Impacts

All alternatives except the No Action Alternative and Alternative 1,
Purchase Power, would impact the area by providing jobs for constructing/
installing and operating/maintaining power generation facilities. The power
plant alternatives (Alternatives 3, 4, and 5) and CBCP may also impact the
local socioeconomic conditions because the centralized generation of
additional electrical power may encourage development and growth in the area.
It is recognized that, though these are considered "positive" impacts,
development and population growth can in themselves create negative secondary
impacts on the area's environment.

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The No Action Alternative would have an negative impact. Not only would
the lack of additional power generation discourage future development but it
could also effect the existing service area by reducing supply reliability
which could cause periodic brown-outs and black-outs.

4.10 IMPACTS ON LAND USE, RECREATION, AND AESTHETIC CONDITIONS

4.10.1 CBCP

The adopted comprehensive land use plan for Duval County, City of
Jacksonville, is the 2005 Comprehensive Plan. The CBCP site lies in an area
designated for Heavy Industrial - IH. Power plants are permissible uses by
exception in IH zones. A zoning expection to allow CBCP to use the SK
wastewater treatment lagoon information was presented at the Land Use and
Zoning Hearing on February 14, 1989. The exception was approved. The hearing
produced a recommendation that the CBCP certification be found incompliance
with the existing City of Jacksonville land use plan and zoning ordinance.

The area about the site is partly developed. South of the site, about
3,000 feet across the Broward River, is the Gulf Oil tank farm and dock.

About 8,000 feet west of the site, across the Broward River, is the developing
Imeson Industrial Park, comprising a number of large corporate warehouses and
storage areas, and a municipal waste treatment plant. Northwest, north and
northeast of the site are residential areas, ranging from low to moderate
density. The closest homes are about 2,500 feet to the northwest, across the
Broward River from the site. About 9,000 feet to the northwest of the site is
the built-out, moderate-density San Mateo subdivision. The closest homes to
the north and the northeast are about 6,000 feet away, separated from the site
and surrounding 425-acres Seminole Kraft property by pinewoods and wetlands.
No residential areas are adjacent to the site or to the SK property. Just
east of the site and the SK property is undeveloped land and a large cleared
area. Southeast of the site about 3,000 feet is the Hess Oil tank farm and
dock.

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The Jacksonville Generalized Existing Land Use Map (1985) depicts the
larger are around the site as comprising river-oriented industrial, limited
commercial, residential, undeveloped and agricultural areas. Jacksonville
International Airport is about 4 miles northwest of the site. The new SJRPP
coal-fired power plants are about 3 miles east of the site. This part of
Jacksonville appears to be developing at an increasing rate. Since the CBCP
site is within the existing SK industrial site and since much of the larger
area around the site and near the St. Johns River is industrial, it appears to
be consistent with existing land use in the vicinity and therefore should not
degrade the character of the surrounding area.

The construction and operation of the CBCP will adversely impact
residential areas west of the site due to increased levels of noise and dust,
salt drift from cooling towers, stack emissions, coal trains, and traffic.
Aesthetically, the new plant and plant facilities will be an intrusion on the
exisitng view, but the new plant will also look more modern and attractive
than the old SK paper mill.

Salt drift from the cooling towers may slightly affect some ornamental
plants that are salt-sensitive around homes to the west of the Broward River.
Groundwater drawdown by the plant may slightly reduce the yield of wells of
homes and farms in the immediate plant area.

4.10.2 Alternatives

The No Action Alternative and Alternative 2, Residential Solar Water
Heaters would have no impact on land use, recreation, and aethetics.
Alternative 1, Purchase Power, would have no local impact.

The power plant alternatives (3, 4, and 5) would have temporary minimal
impact on aesthetics during construction. Operation-related impacts are
considered minor because the site is an existing industrial site that has been
previously disturbed by development activities.

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4.10.3 Comparison of Impacts

The only impacts are those of the power plant alternatives which are
similar to those expected for CBCP and are considered minor.

4.11 TRANSPORTATION IMPACTS

4.11.1 Construction - Related Impacts

4.11.1.1 CBCP

The impacts of construction related traffic in the site area will
affect Heckscher Drive, Main Street, and Eastport Road. Little or no barge
traffic is expected on the St. Johns River during construction.

The year of 1991 will be the peak employment period (633 workers)
with 90 percent of the workforce expected to arrive between the hours of 7:00
and 8:00 A.M. and leave between 3:30 and 4:30 p.m. Assuming an average of 1.2
persons riding in each car, approximately 522 trips. These 1044 daily trips
were assigned to the roadways based on the projected location of the work
force, and the area from which it would be coming. In addition to the work
force, many trucks are expected to enter and leave the site during 1991, the
peak construction year.

Based on the comparison between the peak hour volume and th
capacity, two of the roadways, Hechscher Drive and Eastport Road, will be
exceeding the level permitting free flowing traffic. This would indicate that
the intersections along Heckscher Drive, particularly the intersection with
Eastport Road, will probably exceed intersection capacity.

The influx of the CBCP work force and the continued growth in this
particular area will temporarily (through the construction period) affect
traffic conditions along these roadways. The existing intersections of the
1-95 spur to Heckscher Road and it's intersection with Hechscher Drive going
toward Main Street are presently experiencing some congestion during peak
periods. With additional traffic, this problem will become more severe as

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will the left turn lane from the north at the intersections of Heckscher Drive
and Main Street. Additionally, turning traffic at the intersection of
Eastport Road and Hechscher Drive, presently an intersection of two-lane
roads, will also experience delays. Traffic control will become necessary.

4.11.1.2 Alternatives

Minor traffic congestion would occur during construction of power
plants for Alternatives 3, 4, and 5.

4.11.2 Operation-Related Impacts

4.11.2.1	CBCP

The effects of coal trains entering and leaving the CBCP site will
be the most significant traffic impact during CBCP operation. All railroad
traffic to and from site must cross Baisen Road, Eastport Road, and Main
Street at grade level crossings. The present infrequent passage of trains at
these crossings does not cause a traffic problem. The resulting stoppage of
vehicular traffic on Main Street or New Berlin Road by coal trains to or from
the CBCP site will impair vehicular traffic two times a week on average.
Individual intersections are expected to experience delays of approximately 8
minutes. Simultaneous blocking of all intersections would only delay traffic
by approximately 3 minutes. Particular concern has been expressed for the
passage of emergency vehicles to the San Mateo subdivision. Access to the
development for ambulance services and the fire department will always be
available from the south.

4.11.2.2	Alternatives

The major transportation impact during operations would be caused by
the rail delivery of coal to the power plant for Alternatives 3, 4, and 5.
The trains would be expected to block public roadways when they come and go
from the plant site similar to the conditions expected for CBCP. Also
vehicular traffic to and from the power plant site could conjest the traffic
on local public roads.

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4.11.3 Comparison of Impacts

The power plant alternatives (Alternatives 3, 4, and 5) would have
impacts similar to CBCP resulting from coal deliveries by rail and traffic
coming to and from the plant site.

The No Action Alternative and Alternative 2, Residential Solar Water
Heaters would have no impacts. Alternative 1, Purchase Power, would have no
local impact.

4 .12 ENERGY IMPACTS

4.12.1 CBCP

Cogeneration means the simultaneous production of electricity and useful
thermal energy from the same fuel. Generally speaking, cogeneration is a more
efficient use of a given quantity of fuel than would be two separate
facilities, one producing electricity and the other producing useful thermal
energy. CBCP will burn coal to produce electricity for sale to FP&L and steam
for the adjacent SK paper mill. In so doing it has the potential to make more
efficient use of fuel than would the combination of a freestanding power plant
of the same design and capacity and the SK paper mill.

Efficiency of fuel use itself, however, is not a sufficient reason to
certify a proposed power plant; it is also necessary, under Section 403.519,
FS, that there exist a need for the electricity to be produced by the pwer
plant. This need, or lack of it, is determined by the FPSC. The FPSC has
heard AES argument that a need exists for the power to be produced by CBCP,
and has rendered a judgment that there is a need.

It is conceivable that CBCP might not be as efficient a producer of
electricity, overall, as a modern base-load power plant, which would
ordinarily be the means chosen by an electric utility to meet a demand for
more electricity. The AES does state in the SCA that CBCP will be more
efficient (8200 Btu/KWh), than the FPSC avoided unit heat rate (9790 Btu/KWh).

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4.12.2 Alternatives

The residential solar heaters of Alternative 2 would have a positive
energy impact because they generate power using an inexhaustible energy
source, the sun. The power plant alternatives (Alternatives 3, 4, and 5) all
proposed to use coal as a fuel. Though domestic coal supplies are plentiful,
coal is considered a nonrenewable fossil fuel. Subsequently, the energy
impact of the power plant alternatives is considered negative.

4.12.3 Comparison of Impacts

The power plant alternatives (Alternatives 3, 4, and 5) would, like CBCP,
be considered to have a negative energy impact because of their use of fossil
fuel, coal. The Residential Solar Heater Alternative is considered to have a
positive impact because of its use of the sun.

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CHAPTER 5

SUMMARY OF POTENTIAL
ADVERSE IMPACTS OF THE
PROPOSED PROJECT AND
APPLICABLE MITIGATIVE
MEASURES

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5.0 SUMMARY OF POTENTIAL ADVERSE IMPACTS OF THE
PROPOSED PROJECT AND APPLICABLE MITIGATIVE MEASURES

This chapter summarizes Che potential adverse impacts which could result
from CBCP (Section 5.1) and appropriate measures which are available to
mitigate these impacts (Section 5.2). Sections 5.3, 5.4, and 5.5 summarize
unavoidable adverse impacts, effects of CBCP on short- and long-term
productivity, and those resources which would be permanently committed by
implementation of CBCP.

5.1 SUMMARY OF ADVERSE IMPACTS

This section summarizes the adverse impacts which could result from the
construction and operation phases of CBCP.

5.1.1	Air Resources

The primary air pollutant emitted during construction is fugitive dust
and open burning emissions (particulates, CO. hydrocarbons, S0X and N0X).

These impacts are expected to be minimal and of short duration.

CBCP units will burn coal and wood waste. Impacts on air quality will
include emissions such as SO2, N0X, CO, particulate matter and other minor
constituents. These emissions will be limited by use of control technology
considered to be the best available. Fugitive dust from coal, limestone, and
ash handling will be controlled by a variety of methods to reduce adverse
impacts. It is expected that the CBCP will not contribute significantly to
violations of ambient air quality standards and PSD increment restrictions.

5.1.2	Surface Water Resources

Construction activities will impact surface waters in the St. Johns
River. The primary activities affecting these water bodies are the
construction dewatering and stormwater runoff overflow. Storage areas runoff
and yard area runoff will go to the SK discharge system which outfalls to the
river. Dewatering wastes will be discharged to the SK discharge system via
the SK once-through cooling water effluent line. Operation-related discharges

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include cooling Cower blowdown and yard area runoff which will go to the SK
discharge system. In addition there will be boiler blowdown which will be
discharged to the cooling tower for reuse and low volume wastes, metal
cleaning wastes, and storage area runoff which will be discharged to the SK
IWTS. Cooling tower blowdown effluent and construction dewatering effluent
will go to the SK discharge system and may on occasion violate or exacerbate
existing violations of state water quality criteria for the parameters
aluminum, total residual chlorine, copper, iron, mercury and silver. Water
quality sampling has indicated that the St. Johns River occasionally contains
these parameters in concentrations approaching or exceeding the criteria. The
cooling tower will increase the chemical concentrations of the cooling water
up to 4.6 times the original concentration. The coal pile runoff and metal
cleaning wastes may all contain quantities of the above mentioned parameters.
AES has requested a mixing zone for iron to allow compliance when ambient
water quality is better than the criteria and variances when ambient levels of
iron exceed the criteria.

CBCP solid waste holding area will cover no more than two acres. The
pelletized ash/limestone will be stored in a lined area. Coal pile runoff
will be collected and treated. Leachate from the SK paper mill lime mud piles
which has contributed amounts of heavy metals to the groundwater on the site
is proposed to be eliminated by moving the lime mud to an unlined location
on-site where it will then be covered.

5.1.3 Groundwater Resources

Groundwater elevations will be lowered during construction due to
dewatering around deep foundation excavations. The dewatering should not
cause any noticeable effects on private or agricultural wells in the area.
These construction impacts will be temporary.

Groundwater withdrawals during operations are expected to average 5.44
mgd with an instantaneous maximum demand of 7.0 mgd. Groundwater modeling
efforts done under the direction of AES concluded that the proposed withdrawal
of 7.0 mgd will not cause adverse impacts to existing legal users or cause
adverse water quality problems. USEPA review of the groundwater modeling
documents found that a more sensitive analysis is needed to justify the stated
conclusions (refer to Section 3.3.2).

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5.1.4 Geological Resources

Solid waste will be generated by CBCP from a number of sources. The
largest quantity of solid waste will be generated by the CFB system, referred
to as bed ash. Coal combustion ash, in the form of fly ash, is the other
major solid waste. Bed ash is to be pelletized and transported to a solid
waste holding area. Fly ash will be pneumatically conveyed to temporary
storage silos. Both solid wastes are expected to be transported to a landfill
outside the State of Florida. Subsequently local geological resources will
not be impacted.

5.1.5	Aquatic and Terrestrial Ecology

In general, the use of the existing SK paper mill site and the proposed
rail spur off the existing rail line does not constitute an important loss of
wildlife habitat. However, the construction of the rail spur and new line mud
disposal area will affect some of the resident gopher tortoise (Gopherus
polyphemus) population. It should be noted that the den of the gopher
tortoise is extremely important as a retreat or hibernaculum to no less than
30 vertebrate an invertebrate species, and many of these organisms rely
exclusively on the tortoise borrow for shelter. Because the area designated
for CBCP has been previously cleared for pulp mill operations, thereby
reducing the value of this community as a habitat for wildlife, impact on the
surrounding areas from this project should be minimal.

5.1.6	Sound Quality

Construction noise levels (excluding pile driving and steam blowout of
boiler tubes) will be less than 65 dB(A) which is above EPA's guideline of 55
dB(A) at the nearest residential area. This could be an annoyance to outside
activities at residences near the plant. Steam blowout will cause high noise
levels at the nearest residence. Steam blowout will occur intermittently over
a two week period. Noise levels of 80-90 db(A) will definitely startle
residents.

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Noise from operation of CBCP should not greatly increase noise levels in
the area. The operation of SK paper mill and traffic along Heckscher Drive
will tend to mask operational noise of CBCP. Noise of increased rail traffic
delivering coal will temporarily disturb some neighborhoods.

5.1.7	Cultural Resources

The Division of Historical Resources determined that the site is unlikely
to contain significantly archaeological or historical sites. In addition, the
CBCP site should be far enough away from the Fort Caroline National Monument,
Kingsley Plantation, and other historic, scenic, and cultural areas as well as
state parks and recreation areas that they should not be affected by the
construction of the plant or coal unloading facility.

5.1.8	Socioeconomic Conditions

Since the SK site already has a paper mill operating, the addition of a
new cogeneration plant on adjacent property is not expected to create
significant sociological impacts other than induced traffic delays caused by
coal trains. For this reason, the economic impacts should primarily be felt
in terms of financing rather than in area wide support service demands or
other local costs.

5.1.9	Land Use. Recreation, and Aesthetics

The CBCP site has been found by the Governor and Cabinet of the State of
Florida to be in compliance with local land use plans and zoning regulations.
In addition, the JPD found the project to be consistent with the North
District Plan. Subsequently, no adverse impacts are noted for land use,
recreation, and aesthetics.

5.1.10	Transportation

The roadways that are most likely to be impacted by CBCP are Heckscher
Drive, Main Street, Eastport Road and New Berlin Road. The most severe impact
is expected to occur at the intersection of Eastport Road and Heckscher Drive,

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presently an intersection of two-lane roads. Construction traffic to and from
the CBCP site will likely cause congestion at this intersection. The turning
traffic, from Heckscher onto Eastport is expected to significantly increase.

The effects of coal trains entering and leaving the plant site will be
the most significant traffic impact during plant operations. All railroad
traffic to and from CBCP must cross Baisden Road, Eastport Road, and Main
Street at grade level crossings in the San Mateo development. It is estimated
that CBCP will receive two train loads per week on average. The three roads
would be blocked for approximately eight minutes each but all three streets
will only be simultaneously blocked for approximately four minutes. Even when
all three roads are blocked, access to the San Mateo development from the
south is still available. Ambulance services and the fire department will
always have access, should that be necessary, at the time the train is either
entering or leaving CBCP.

5.1.11 Energy Resource

The use of CFB boilers and the production of process steam during the
generation of electrical power makes the CBCP an efficient user of energy. In
view of these items and given the large domestic supply of coal, no adverse
impacts on energy resources are anticipated.

5.2 IDENTIFICATION AND EVALUATION OF AVAILABLE MITIGATIVE MEASURES

This section summarizes the measures which are available to mitigate
potential impacts of the construction and operation of CBCP on the natural and
man-made environment.

5.2.1 Air Resources

Appropriate methods of dust control and dust emission prevention will be
used to mitigate effects of construction in the vicinity of CBCP. Air quality
control rules of the State of Florida for fugitive dust emissions and open
burning will also be met (Chapter 17-2.04(3) and Chapter 51-2 FAC). To comply
with these regulations, all reasonable precautions will be taken to prevent

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fugitive dust emissions during construction. Such precautions will include
using asphalt, rock or shell, oil, water, or dust-suppression chemicals for
the control of dust from grading and clearing operations and on dirt roads.
Other measures of fugutive dust control include careful operation of on-site
equipment, reduction of vehicle speeds on unpaved areas and rapid revegetation
of cleared areas after construction.

During construction, vegetation will be cleared. Open burning of debris
must comply with the following conditions:

o Burning will be performed between 9:00 a.m. Eastern Standard Time
(EST) and one hour before sunset; at other times, a forced draft
system will be used;

o The burning location will be at least 45 meters (50 yards) from the
nearest occupied building or public highway;

o Piles will be no larger than can be burned within the designated
time;

o Moisture content and composition will be favorable for good burning;
and

o Smoke emissions will not exceed 40% capacity or Number 2 on the
Ringelmann chart except during startup.

In addition, burning should be conducted during periods of good atmospheric
dispersion.

Operation-related 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
CBCP to plant trees in order to mitigate carbon dioxide "greenhouse" effects.

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5.2.2

Surface Water Resources

Potential impacts on surface water resources during the construction
phase will be related primarily to erosion and sedimentation. Accelerated
erosion can be controlled by compaction of embankments, early soil
stabilization, limiting the size of exposed areas, maintenance of relatively
flat grades, stabilization of stormwater flat grades, and stabilization of
stormwa|:er outlets and flat bottom ditches as well as other appropriate
erosion control techniques.

Sedimentation can be controlled during construction by use of sediment
control basins and traps, filter berms, straw bales, perforated riser pipes at
drainage structures, or other applicable devices as appropriate. Also
included for controlling runoff and sedimentation is the use of a construction
runoff retention pond (Storage Area Runoff Retention Pond) and temporary
sedimentation ponds. An additional mitigative measure could include the
construction of a sand/gravel filter as a part of the retention pond for
improved removal of silt.

Discharges from the wastewater treatment system can contribute
contaminants to the St. Johns River which already contains excessive
of those contaminants. Proper operation of the wastewater treatment
use of mixing zones and approval of variances for some metals should
the impacts of the discharges.

5.2.3 Groundwater Resources

CBCP will have an adequate supply of fresh water from the SK wells for
its cooling tower system. Because there is concern about the adequacy of the
fresh water supply in Duval County and potential salt water intrusion into the
drinking water aquifer, the future use of reclaimed water from the
Jacksonville sewage treatment system and/or CBCP process waters is
recommended. It is also recommended that AES consider treatment and use of
brackish river water as a source for cooling.

amounts
facility,
mitigate

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5.2.4 Geological Resources

Disposal of solid waste is expected to be done off-site by the coal
supplier. Subsequently no adverse impacts are expected to occur locally and
no mitigative measures are presented.

5.2.5 Aquatic and Terrestrial Ecology

Clearing the site of natural vegetation should be kept to a minimum to
minimize erosion and to reduce the negative impacts to terrestrial
communities. A small buffer should be maintained around each of the wetlands
contiguous with the Broward River. The natural buffer should serve to
slightly filter any noise from plant operations and provide a slight visual
barrier to CBCP. However, the validity of using a small buffer to protect the
adjacent wetlands and estuary remains dubious.

No wide-spread negative impacts on ecologically sensitive areas are
expected. Mitigative measures should be utilized to minimize adverse impacts
such as the use of sedimentation ponds to intercept runoffs from site
preparation and plant construction which will prevent significant impacts
resulting from increased turbidity and TSS inputs to the river populations
dependent on the marsh and river for food or cover. The pond will be designed
to provide a 24 hour retention of runoff produced by a 10 year, 24 hour design
storm and retain accumulated solids. Fresh-water effluent from the
sedimentation pond will overflow a weir in the river. It is recommended that
a sand/gravel filter be added to the retention pond for improved removal of
silt.

Of special concern is the protection of the gopher tortoise populations
which have already been significantly reduced as a result of operations which
are currently underway. Because the significance of the impacts incurred by
this species due to additional disturbances cannot be firmly predicted, it is
important that maximum protection be afforded the gopher tortoise. It may be
necessary to relocate gopher tortoise populations as well as some of the
associated commensal species. The relocation of affected animals should be
done in consultation and conformance with the Game and Freshwater Fish

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Commission requirements. Also it is recommended that with the exception of
that area occupied by CBCP components, exposed areas be revegetated with pines
and other vegetation native to the site and beneficial to wildlife.

5.2.6	Sound Quality

Noise levels due to the operation of construction equipment should be
minimized by requesting contractors to make use of modern low noise level
equipment. Most construction activities should take place during daylight
hours which would further reduce noise impacts. Steam blowout at the start-up
of each unit is expected to present the greatest noise impact. Such
operations will occur intermittently over a two week period per unit. Steam
blowout should be restricted to daylight hours with prior notice made to the
public.

5.2.7	Cultural Resources

No adverse impact are expected, subsequently no mitigative measures are
presented.

5.2.8	Socioeconomic Conditions

No adverse impacts are expected, subsequently no mitigative measures are
presented.

5.2.9	Land Use. Recreation, and Aesthetics

Since land use impacts are negligible, no mitigative measures are
proposed.

5.2.10	Transportation

Traffic should be controlled by limiting site access to required delivery
vehicles. Employee parking should be restricted to a designated area located
near the construction office. Any damage to the public road surfaces
resulting directly from CBCP-related traffic should be repaired.

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Rail deliveries of coal should also be scheduled Co avoid "rush-hour"
traffic between 7:00-9:00 a.m. and 4:00-6:00 p.m.

5.2.11 Energy Resources

No adverse impacts are expected, subsequently no mitigative measures are
presented.

5.3 UNAVOIDABLE ADVERSE IMPACTS

CBCP would result in certain adverse environmental impacts despite the
emphasis on state-of-the-art impact control technology in all project phases.
Some of the impacts are unavoidable consequences of a commitment to project
objectives. Others, while avoidable, are regarded as insignificant compared
to the cost of their elimination. Every effort should be made to ensure the
most environmentally favorable trade-offs between construction and operation of
the generating units and the use of air; land, and water resources.

5.3.1 Atmosphere Resources

An increase in pollutants released to the atmosphere as a result of the
CBCP would result. The emissions of N0X, SO2, CO and particulates from CBCP
would not result in a violation of Federal or State ambient air quality
standards. Air emissions would use up portions of available Prevention of
Significant Deterioration Class II increments at points close to the facility
This would not preclude future industrial development in the site region. No
adverse effects on the nearby Okefenokee Class I area are projected.

Emissions of SO2 and N0X have been associated with acid precipitation.
To date, however, only a general relationship has been established. The
relationship between emissions of the precursor pollutants from a particular
source and acid in a particular area remains speculative. The most highly
publicized relationship is that between acid rain in the northeastern United
States and Canada. It is therefore difficult to determine how much of an
adverse impact CBCP would produce with respect to acid rain.

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Emissions of CO2, methane, CFC's, NOx and a variety of low-volume gases
have been associated with global climate change referred to as the greenhouse
effect. These greenhouse gases collectively function to retain heat energy,
effectively warming the earth's surface. A mitigative measure to off-set the
increasing concentrations of these gases in the atmosphere, particularly CO2 ,
is through reforestation.

One feature that will mitigate some of the impact of CBCP is the use of
stringent sulfur emission controls during operation. CBCP will utilize flue
gas desulfurization (FGD) via a fluidized bed of limestone sulfur emissions.
NOx will be controlled by boiler design. Such control will also help mitigate
the rainfall acidification problem. The primary source of N0X appears to be
automobile emissions.

5.3.2 Land Resources

A total of 35 acres of previously disturbed land would be preempted from
other uses during the life of the project. Since this site does not include
significant areas of wildlife habitat and is zoned for industrial use no
unavoidable adverse impacts are anticipated.

5.3.3. Water

Discharge of cooling tower blowdown and wastewater treatment plant
effluent would cause or exacerbate additional violations of Florida Class III
water quality standards for several trace metals when water quality of the
River approaches or exceeds the applicable standards. This would have an
adverse impact on water quality and aquatic life in the St. Johns River
estuary. Also the use of large amounts of potable groundwater (average of
5.44 MGD) from the Floridan Aquifer, which is already experiencing decreasing
levels, could have an adverse impact on local water supply and quality.

5.3.4 Sensitive Areas

No sensitive areas are located within the CBCP site boundaries therefore
no unavoidable adverse impacts are expected.

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5.4 RELATIONSHIP OF SHORT-TERM USES OF MAN'S ENVIRONMENT AND MAINTENANCE AND
ENHANCEMENT OF LONG-TERM PRODUCTIVITY

During the proposed 30-year life of CBCP, the air, water, and land
resources of the site will be committed to the production of electric power.

The production of electricity during the operating life of CBCP will
contribute to tourism and other industries within FPL service area, the
utility purchasing power from CBCP. This electric power will accommodate the
projected increase in the population of the region and the projected
electrical needs for the FP&L system.

5.5 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES

The proposed plant will consume an estimated 33.15 million tons of coal
during its 30-year life. The consumption of fuel oil for start-up and flame
stabilization is expected to be 4.80 million gallons over the life of the
facility.

The CBCP will use an estimated 3.0 million tons of limestone during plant
life which will be irretrievably committed.

Materials like concrete cannot be recycled and thus will be irretrievably
committed to the construction of CBCP. Other materials such as steel and
aluminum may be reclaimed if it is economically feasible. Other construction
requirements such as labor and capital will also be irretrievably committed to
CBCP.

Land containing a variety of habitat types would be permanently committed
in areas to be used as solid waste disposal areas.

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CHAPTER 6

SUMMARY OF SAR / EIS
FINDINGS

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6.0 SUMMARY OF SAR/EIS FINDINGS

The basic level of detailed information available for the alternatives to
CBCP and the broad economic and environmental assumptions required to make
comparisons among the alternatives prevents the identification of any one of
the alternatives as being clearly superior. However, certain generalizations
regarding the evaluation of the No Action Alternative, the proposed project
(CBCP), and Alternatives 1 through 5 can be stated along with a recommended
course of action.

6.1	SUMMARY OF ECONOMIC ANALYSIS

The economic screening of the alternatives and the proposed project
(Section 2.8.4) focused primarily on the cost savings that could be realized
by displacing oil-fired generating capacity. This analysis was based solely
on the construction/installation and operating costs of each alternative and
did not take into account variations in fuel costs and transmission costs.
Consequently, the findings of this analysis serve primarily as an indicator of
the economic comparability of the alternatives of oil savings rather than as
an indication of the most cost-effective alternative overall.

With respect to the primary issue on which the project is currently being
proposed (generation of 225 MW of electrical power that is not dependent on
oil or natural gas) several of the alternatives appear to be attractive,
particularly the gasified coal-fueled combustion turbine and combined cycle
power plants (Alternatives 3 and 4, respectively).

6.2	SUMMARY OF ENVIRONMENTAL ANALYSIS

The environmental analysis of CBCP and the alternatives (Chapter 4.0)
focuses on the potential impacts of implementing the projects on eleven
resource areas. This analysis was based on site- and project-specific data
and detailed analyses for the CBCP site and impact area while more general
data and analyses were utilized for the alternatives. Consequently, although

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impact analyses were carried out for each alternative, the level of detail
provided in these analyses varies significantly between CBCP and the
alternatives.

Tables 6-1 and 6-2 were prepared to summarize the environmental impacts
expected to occur during construction/installation and operations. It is
estimated that construction activities for the power plant alternatives
including CBCP, will take place over a 30 month period and that their
operational life will be 30 years. It should be noted, the construction and
maintenance of transmission lines for the purchase power alternative and the
power plant alternative are not addressed in this evaluation.

6.2.1	Construction-Related Impacts

Table 6-1, environmental impact during construction, shows the No Action
Alternative to have no impact. The Purchase Power alternative is stated to
have "impact shifted away from local areas". This is because the evaluation
only addresses local (Jacksonville/Duval County area) impacts and not impacts
at the site of purchase power generation which in turn could be as significant
as those impacts created by the power plant alternatives and CBCP.

Alternative 2, Residential Solar Water Heaters, 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 and energy consumption is required
to make the units but these impacts would be extremely minor in comparison to
the power plant alternatives. The impacts for the remaining power plant
alternatives are equivalent to those expected by CBCP construction. It should
be noted that these impacts would be temporary (for the life of the
construction phase) and with appropriate mitigation, the impacts could be
lessened if not eliminated.

6.2.2	Operation-Related Impacts

Table 6-2 summarizes the impacts expected during the operations of the
various alternatives. As was the case for construction, activities, the
Purchase Power Alternative (Alternative 1) shifts any environmental impacts
away from the local area. As noted in Section 2.8.3.2 this alternative also

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TABLE 6-1
POWER SUPPLY ALTERNATIVES
SUMMARY OF ENVIRONMENTAL. IMPACTS DURING CONSTRUCTION/INSTALLATION

I

u>

Alternative

Air
Quality

Surface
Water
Quality

Groundwater
Quantity and
Quality

Aquatic anJ
Terrestrial
Ecology

Sound
Quality

Cultural
Resources

Socioeconomic
Conditions

Ldiul Use,
Recreation,
and Aesthetics

Transportation

Energy
Resources

Conclusions (1)

1 - Purchase Power

No Local
impact

No Local
impact

No Local
Impact

No Locul
Impact

No Local
Impact

No Local
Impact

No Local
Impact

No Local
Impact

No Local
Impact

No Local
Impact

Impacts shifted
away froin local
area

2 - Residential Solar
Water Heaters

Minimal
impact

No Impact

No Impact

No impact

No Impact

No Impact

Creates fobs

No Impact

No Impact

Minimal
Impact

Decentialned
impacts at
poult of use

3 - Combustion Turbine
Power Plant
(gasified coal-fueled)

Emits fugitive
dust and particulates
due to excavation,
grading, burning, &
traffic

Discharge*
storm and
dewalering runoff

Minimal
Impact

Disrupts
wildlife habitat
(gopher toiti^c)

Generates noise
Jul to pile driving
and ileum blowout

No Impact

Cicaies jobs

Temporary
Aesthetic
Impact

Increases
vehicular traffic
on public roads

Minimal
Impact

Willi appropriate
mitigation
(BMP's) no
long-term local
impact

4 - Combined Cycle

Power Plant
(gasified coal-fuclcd)

Emits fugitive
dust and particulates
due to excavation,
grading, burning, Si
traffic

Discharges
storm and
dcwateung runoff

Minimal
Impact

Disrupts
wildlife habitat
(gopher toilisc)

Generates noise
due to pile driving
and steam blowout

No impact

Creates jobs

Temporary
Aesthetic
Impact

increases
vehicular traffic
on public roads

Minimal
Impact

With a|Tpropnate
mitigation
(BMP's) no
long-term local
impact

5 - Conventional Coal-
fired Power Plant

Emits fugitive
dust and particulates
due to excavation,
grading, burning, A
traffic

Discharges
storm and
dewatering runoff

Minimal
Impact

Disrupts
wildlife habitat
(gopher tortiM.)

Generates noise
due to pile driving
and steam blowout

No Impact

Creates jobs

Temporary
Aesthetic
Impact

Increases
vehicular traffic
on public roads

Minimal
Impact

With a|>propn*tc
mitigation
(BMP's) no
long-term local
impact

6 - No Action

No impact

No Impact

No Impact

No impact

No Impact

No Impact

No Impact

No Impact

No Impact

No
impact

No Impact

7 - CBCP

Emits fugitive
dust and particulates
due to excavation,
grading, burning, &
traffic

Discharges
storm and
dewatering runoff

Minimal
Impact

Disrupts
wildlife habitut
(gopher toitisi.)

Generates noise
due to pile driving
jiiJ steam blowout

No Impact

Cicales jobs

Temporary
Aesthetic
Impact

Incieases
vehicular traffic
on public roads

Minimal
Impact

With appropriate
mitigation
(BMP's) no
long-term local
impact

(1) BMP - Best Management Piacltces

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TAHUi 6-2
TOWER SUPPLY ALTERNATIVES
SUMMARY OF ENVIRONMENTAL IMPACTS DURING OPERA TIONS

Alternative

Air
Quality

Surface
Water
Quality

Groumiwiitci
Quanity and
Quality

Aquatic and
Teireslnal

Ecology

Sound
Quality

Cultural
Resources

Socioeconomic
Conditions (1)

(.iiiui Uoe,

kcciculioit,
and Aclhchcs

TranR|M>Mdlion

lliicigy
Resources

Conclusion

1 - Pure hate Power

No Local
Impact

No Local
Impact

No Local
Impact

No Local
Impact

No luteal
Impact

No Local
Impact

Potentially
provides jobs
away from
local area

No Local
Impact

No Local
Impact

No Local
Impact

Impact shifted away
from local area but
may have high trans-
mission costs and
low reliability and
does not produce
steam for SK

2 - Residential Solar
Water Heaters

No
Impact

No
Impact

No
Impact

No
Impact

No
Impact

No
Impact

Create
maintenance

jobs at
point of use

No
Impact

No
Impact

Uses a
renewable energy
source

Coordination of
implementation complex,
high maintenance

requiicmenla,
requues a backup
system, and does not
produce steam for SK

3 - Combustion Turbine
Power PUm
(giufied coil-fuelul)

On ii cleaned to
remove S02 and
particulates prior to
use NOx ii conlrollcd
by combustion
temperature May
emit significant
level* of COZ

Discharges include
significant levels of
arsenic, chiorniwn,
heat cop|)cr. iron,
mercury, silver, oil
and grease. cadmium,
aluminum, lead, zinc,
pH. and residual
chlonne

Large consumption

of potable
groundwater could
lower supply and
increase sail water
intrusion

Development of
land impacts
habitats of wildlife

and wastewater
effluent impacts fish

Sj>oradic impact
due lo train
deliveries and
luffic

No effect
pci

consultation

Provides OA.M
jobs locally

Minimal impact
lo existing
industrial
sue

Coal deliveries
by rail may cause
traffic conjcslion at
public road crossings
and vehicular tiaffic
would be increased
to snd from the site

Uses a non-
renewable
fossil fuel
but provides
pollutant control
before combustioo
by washing gas
and is very fuel
efficient

Coal-gasificstioo is

just becoming
commeicislly viable,
high maintenance, and
does not produce
for SK

4 - Combined Cycle

Power Plant
(gasified coal-fueled)

Oat u cleaned to
remove S02 and
pamculatea prior to
uae NOx it controlled
by combustion
temperature May
emit significant
levela of C02

Discharges include
significant levels of
arsenic, chromium,
heat, copper, iron,
mercury, silver, oil
and grease, cadmium,
aluminum, lead. zinc.
pH, and residual
chlonne.

Large consumption

of potable
groundwater could
lower supply and
increase salt water
intrusion

Development of
land impacts
habitats of wildlife

and wastewater
effluent impacts fish

S|Hiradic impact

due lo tiain
dclivenei and
tiaffic

No effect
per
consultation

Provides O&M
jobs locally

Minimal impact
lo e listing
industrial
site

Coal delivcnes
by rail may cause
traffic coiijestiou at
public road crossings
and vehicular traffic
would be increased
to and from the site

Uses a non-
renewable
fossil fuel
but provides
pollutant control
before combustion
by washing gas
and is very fuel
efficient

Coal-gasification is

just becoming
commercially viable,
high maintenance, and
can produce process
steam for SK

5 - Conventional Coal-
fired Power Plant

May emit significant
levels of S02, NOx.
CO and particulates
requiring extensive
poit-cote bullion
pollutant control

Discharges include
significant levels of
arsenic, chromium,
heal, copper, iron,
mercury, silver, oil
and grease, cadmium,
aluminum, lead, zinc.
pH, and residual
chlonne.

Large consumption

of potable
groundwater could
lower supply and
increase salt water
intrusion

Development of
Isnd impacts
habitats of wildlife

and wastewater
effluent impacts fish

Spoiadic impact

due to traiu
deliveries and
tiatfic

No effect
per
consultation

Provides OAM
jobs locally

Minimal impact
lo existing
industrial
tile

Coal deliveries
by rail may cause
traffic conjcslion at
IHiblic road c tossings
and vehicular tiaffic
would be increased
lo and from the ailc

U»ea a non-
renewable
fossil fuel
and is lesi fuel
efficient than new
technologies

Requires cxpenaive
pollution control
facilities. aikJ can
produce process steam
for SK

6 - No Acuoo

No Impact

No Impact

No Impact

No Impact

No liii|>act

No Impact

No Impact

No Impact

No Unpad

No Impact

Continued uae of old
technology al SK will
see continued air
emission problems

7 - CBCP

S02 and NOx are
controlled during
combustion May emit
significant levels of
CO and particulates

requiting posl-
combustion control

Discharges include
significant levels of
arsenic, chromium,
heat, copper, iron,
mercury, silver, oil
and grease, cadmium,
aluminum, lead, line,
pll, and leuidual
thloi me

Large consumption

of potable
groundwater could
lower suj>ply and
increase ult walei
imIiumoii

Dcvclofmicnl of

land impacts
habitats of wildlife

and wastewater
clMucnl impacts fish

S|H)iadie uii|>ai-i
doe lo tiain
dclivcncs anJ
tiallic

No cIIclI
per
consultation

Provides O&M
f<>t>s locally

Minimal impact
lo existing
industrial
site

Coal dclivcncs
by rail may cause
tiallic congestion al
>ul)lic road crossings
rfui velii^ulai lialfic
would be incieaned
lo and 1 loin the »i(c

Uses a non-
renewable
fossil fuel
but is very fuel
ctlicienl

Proven commercially
viable (ecltnology
but CHli units this
size arc new, and can
ptodocc iicam for SK

-------
may require the need for additional transmission facilities at a very high
cost and that outside utilities (utilities other than FP&L) may not have the
extra power to sell. Subsequently, the alternative has low reliability. Also
this alternative can not supply process steam to the SK paper mill and result
in the continued use of old and pollutant-generating technologies at the SK
paper mill.

Alternative 2, Residential Solar Water Heaters seems very attractive
because it is environmentally benign in that it has very minimal if no adverse
impacts and uses an inexhaustible energy source, the sun. The major drawbacks
to this alternative is the complexity of coordinating implementation efforts,
the question of who finances and installs the units, and more importantly, who
is responsible for maintaining the units. Though these units require minimal
operational efforts they have a history of high maintenance needs. If
maintenance is left to the individual residents, the quality control of
maintenance efforts, and subsequently the useability of the units would be in
question. On the other hand, requiring the utility, in this case FP&L, to be
responsible for maintaining 730,000 decentralized units (refer to Table 2-4)
would make this alternative managerially and economically unattractive. In
addition, this alternative would require a 100% backup system for inclement
weather conditions. Heated water storage in the units would not last much
beyond 3 days. A week-long period of inclement weather blocking the sun could
put a strain on the utility supplying the backup power. Consequently this
alternative does not necessarily increase the utility's reserve margin. Also
this alternative can not supply process steam to the SK paper mill and result
in the continued use of old and pollutant-generating technologies at the SK
paper mill.

Alternative 3, the Combustion Turbine Power Plant fueled by gasified coal
has environmental impacts equivalent to the proposed project, CBCP, but is the
only power plant alternative that does not include the production of process
steam for the SK paper mill and result in the continued use of old and
pollutant-generating technologies at the SK paper mill. Combustion turbine
technology is a proven power production technology but coal gasification,
though environmentally desirable, is a new refining process which is just
starting to come out of the demonstrative stage for commercial applications.
Major environmental impacts include CO2 air emissions during operations.

6-5

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Alternative 4, the Combined Cycle Power Plant fueled by gasified coal has
environmental impacts equivalent to the proposed project, CBCP, and can also
produce process steam for SK. Like Alternative 3, the power production
technology has been commercially proven but the coal gasification technology
is still relatively new for commercial applications. Major environmental
impacts include CO2 air emissions during operations.

Alternative 5, the Conventional Coal-fired Power Plant can provide
process steam for the SK paper mill but has the most adverse environmental
impacts in comparison to the other alternatives. Its use would require
extensive, expensive post-combustion pollutant controls. Major environmental
impacts include SO2, N0X CO, and particulates.

The No-Action Alternative would have no obvious environmental impacts,
but this alternative could result in the continued use of old and pollutant-
generating technologies at the SK paper mill. In addition, if additional
power is not generated for FP&L as proposed by CBCP, the utility's reserve
margin could fall below acceptable standards resulting in future, periodic
brown-outs or black-outs.

The proposed project, CBCP, consists of a proven technology, CFB units,
but the size proposed is relatively new for commercial applications. This
technology, along with Alternatives 3 and 4, are all considered environmen-
tally low-impact power plant technologies. Many of the adverse impacts of
CBCP which cannot be completely mitigated are a function of its location. The
impact on transportation systems, wildlife habitats, and the exacerbation of
existing water quality problems may not have occurred at another alternative
site. Due to the need to have CBCP close to the SK paper mill for process
steam transport, alternate sites were not considered economically feasible for
operations. Because of this AES has been willing to exert additional effort
toward mitigation of the project impacts.

6.3 ALTERNATIVES TO THE PROPOSED PROJECT

Based on the preceding discussions, it is apparent that viable alter-
natives to the construction and operation of CBCP exist. Alternatives were
developed based on their ability to meet the same economic goals which were

6-6

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identified by the FPSC as the reasons for approving the construction of CBCP.
The alternatives were judged to equal the economic benefits to the CBCP by
satisfying the following criteria:

o the alternative would replace or save oil and natural gas equivalent
to or greater than the oil displaced by the proposed project;

o the alternative would provide 225 KW of electrical power; and

o the alternative must be implementable within the proposed time frame
of CBCP (1996)

The selection of one of the alternatives over the proposed project would
satisfy the economic need but it would not necessarily satisfy the need for
process steam at the SK paper mill.

6.4 RECOMMENDED COURSE OF ACTION

6.4.1 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 its
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 utlities 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:

o Ambient air quality will be improved in the Jacksonville area and in
the Okeefenokee Swamp area.

6-7

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o Thermal waCer 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.

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

o 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:

o SNRC is the preferable alternative .for N0X control unless it can be
shown clearly that it does not represent BACT.

o 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.

o The addition of sand/gravel filters in the retention ponds for
improved removal of silt is a viable alternative.

6.4.2 FDER's Recommendations'

FDER has recommended certification of CBCP. This recommendation is based
on the following rationale:

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

6-8

-------
o 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.

o Discharges from the 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
from some metals would allow certification to be granted.

If the CBCP 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 CBCP is in conformance with the
applicable standards, regulations and laws of this State and that the facility
have minimal adverse impacts on the environment.

6.4.3 Unresolved Issues

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

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 final 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

6-9

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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. Re-evaluation 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 in the Final EIS.

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 discharge into
the SK system prove to be more toxic than presently anticipated and 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 the 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.

6-10

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Groundwater - 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 related 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 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.

6-11

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CHAPTER 7

LIST OF PREPARERS

-------
7.0 LIST OF PREPARERS

7.1 US ENVIRONMENTAL PROTECTION AGENCY, REGION IV

Heinz Meuller

Marion Hopkins

Chief, Environmental Policy Section
Federal Activities Branch

Projet Monitor, Environmental Policy Section

Charles H. Kaplan, P.E. NPDES Permit Coordinator

National Expert, Steam Electric/Water

Wayne J. Aronson

David W. Hill

Harry Desai

Frank M. Redmond

Chief, Program Support Section
Air Programs Branch

Regional Expert Engineer
Ground Water Technology Unit

Acting Chief
Florida/Georgia Unit
Waste Engineering Section

Chief

Wetlands and Coastal Programs Section

7.2 FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION

Hamilton S. Oven, Jr.

Max Linn

Pradeep Ravel

Barry Andrews

Jerry Owen

Bob Leetch

Frank Watkins

Darryl Joyner

Jan Mandrup-Poulsen

Don Kell

John Reese

Marge Coombs

Administrator

Siting Coordination

Division of Air Resources Management
Division of Air Resources Management
Division of Air Resources Management
Division of Air Resources Management
Northeast Florida District Office
Northeast Florida District Office
Northeast Florida District Office
Division of Water Facilities
Division of Water Facilities
Division of Water Facilities
Division of Water Facilities
Division of Water Management

7-1

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Dr. Larry Olsen
Betsy Hewitt
7.3 GANNETT FLEMING, INC.

Thomas M. Rachford, P.E
Marintha K. Bower, P.E.
Robert Hasemeier, P.E.
John Vaklyes, P.E.
Katherine Rothdeutsch
Mark Mummert, Ph.D.

Division of Adminstrative and Technical Services
Office of General Council

, Ph.D. Program Manager
Project Director
Environmental Engineer
Air Quality Specialist
Land Use Planner
Water Resource Specialist

7-2

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CHAPTER 8

PUBLIC PARTICIPATION
AND COORDINATION
EFFORTS

-------
8.0 PUBLIC PARTICIPATION AND COORDINATION EFFORTS

8.1 PUBLIC PARTICIPATION

In accordance with State and Federal regulations, USEPA and FDER have
conducted a public participation program in conjunction with the preparation
of this SAR/EIS. This program consists of: (1) an initial publicly announced
scoping meeting of citizens and leaders from Jacksonville/Duval County and
State and Federal government agencies at which the scope of the proposed
SAR/EIS was discussed and the central issues identified; (2) institution of
changes in the scope of the SAR/EIS which were identified as a result of the
meeting; (3) a formal public hearing to present the results of the Draft
SAR/EIS and receive public comments; (4) distribution of the DEIS for public
review; and (5) publication of comments in the final SAR/EIS.

The public scoping meeting was held on January 24, 1989 at the San Mateo
Elementary School in Jacksonville, Florida. Areas of concern which were
identified at the time included:

o the need for producing power in Jacksonville that would be sold to
FP&L for other areas of the State;

o impacts of coal conveyor proposed to be constructed across the
Broward River below the Hecksher Street Bridge;

o impacts of increased truck and rail car traffic on transportation
corridors;

o potential deterioration of water quality in the Broward River and
the effect that it may have on recreational fishing;

o use of large volumes of high quality groundwater for cooling makeup
water;

o disposal of the waste products that would be produced by plant
operation, and of the lime sludge located on the plant site;

o impacts on the air quality around the Jacksonville area from plant
emissions, especially SO2, CO2, N0X, TRS, and particulates;

o potential for producing acid rain from emissions which in turn would
slowly dissolve or deteriorate structures such as those made from
coquina in Historic St. Augustine.

8-1

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o impacts on wetlands particularly the possible violations of the
objectives of the Conservation Coastal Management Element of the
Comprehensive 2010 Plan prepared by the City of Jacksonville
Planning Department (October 1988); and

o impacts on sound quality due to increased rail traffic and plant
construction and operation.

At this meeting, representatives of USEPA and FDER also explained aspects
of the Memorandum of Understaing between the two agencies and the purpose of
coordinating the review efforts. The representatives identified the basic
responsibilities of each agency. Other meetings have also been held regarding
the proposed CBCP project. On February 14, 1989, a Land Use and Zoning
Hearing was held. The Hearing Officer's recommendation of April 14, 1989, was
that the application for Power Plant Site Certification be found in compliance
with existing City of Jacksonville land use plans and zoning ordinances. The
Florida Public Service Commission held a hearing on April 24 and 25, 1989 in
Tallahasee regarding the need for the project. The Commission issued an order
granting the determination of need on June 30, 1989. The State Certification
Hearings were held in Jacksonville during the weeks of February 5 and 19,
1990. Through these mechanisms and continual day-to-day contact with local.
State, and Federal officials as well as informed individuals, USEPA and FDER
have consistently incorporated the public in this review process.

8.2 AGENCIES, ORGANIZATIONS, AND INDIVIDUALS INCLUDED IN THE DRAFT/SAR/EIS

REVIEW PROCESS

The comments of the following agencies and organizations are directly
requested in the review of this project.

Federal Agencies

US ENVIRONMENTAL PROTECTION AGENCY

Room 537, West Tower
401 M. Street, S.W.

Washington, D.C. 20202

8-2

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Regional Administrator
Region IV

345 Courtland Street, N.E.
Atlanta, Georgia 30365

Department of Agriculture

Deputy Chief
Forest Service
Room 3029, S. Bldg.
Washington, D C. 20250

Assistant Administrator
National Programs Staff
Agricultural Research Service
Washington, D.C. 20250

Director, National Resource
Economic Research Service
Economics Division, Room 412
Bldg. 500 12th Street, S.W.
Washington, D.C. 20250

Administrator
Soil Conservation Service
Room 5105 South Building
Washington, D.C. 20250

Soil Conservation Service
Federal Building
P.O. Box 1208

Gainesville, Florida 32601

8-3

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Department of the Army

Chief of Engineering Division
U.S. Army Corps of Engineers
Jacksonville District
P.O. Box 4970
Jacksonville, FL 32201

Department of Commerce

Economic Development Administration
Special Assistant for the Environment
Washington, D.C. 20230

National Marine Fisheries Service

Regional Director

Duval Building

9450 Roger Boulevard

St. Petersburg, Florida 33702

Department of Energy-

Director of NEPA Affairs
Mail Station E-201, GTN
Washington, D.C. 20543

Energy Research and Development Administration

Office of Environmental Assessment
AEQ-100

800 Independence Avenue, S.W.

Washington, D.C. 20591

8-4

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Federal Energy Regulatory Commission

Commission's Advisor on Environmental Quality
825 North Capitol Street, N.E.

Washington, D.C. 20426

Federal Highway Adminstration

Director, Office of Environmental Quality
Room 3226, Nassif Building
Washington, D.C. 20590

Department of Health and Human Services

Public Health Service
Centers for Disease Control
Atlanta, Georgia 30333

Department of the Interior

Assistant Secretary - Program Development and Budget
Director, Office of Environmental Project Review
Department of Interior
Washington, D.C. 20240

U.S. Fish and Widlife Service
Regional Director
17 Executive Park Drive, N.E.

Atlanta, Georgia 30329

National Park Service
Air Quality Division
P.O. Box 25287
Denver, Colorado 80225

8-5

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Department of Transportation

U.S. Coast Guard
Commander

Seventh Coast Guard District
909 S.E. First Avenue
Miami, Florida 33131-3050

State Agencies

Florida Department of Environmental Regulations

Division of Environmental Permitting

2600 Blairstone Road

Tallahassee, Florida 32399-2400

Department of Adminstration

Bureau of Intergovernmental Relations
Division of State Planning
660 Apalachee Parkway
Tallahassee, Florida 32304

Florida Department of Community Affairs

Bureau of State Planning
2740 Centerview Drive
Tallahassee, Florida 32399

Florida Department of State

The Capitol

Tallahassee, Florida 32304

8-6

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State Historic Preservation Officer

Director, Division of Historical Resources and State Historic

Preservation Officers

Department of State

R.A. Gray Building

Tallahassee, Florida 32399-0250

Florida Game and Fresh Water Fish Commission

Farris Bryant Building
620 South Meridian Street
Tallahassee, Florida 32304

Florida Public Service Commission

Engineering Department
700 South Adams Street
Tallahassee, Florida 32304

Northeast Florida Regional Planning Council

Executive Director

8641 Baypine Road, Suite 9

Jacksonville, Florida 32216

Florida Department of Transportation

District Two

Lake City, Florida 32055

8-7

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Local Agencies

City of Jacksonville

Planning Department
128 East Forsyth Street
Jacksonville, PA 32202

Public Utilities Department
219 Newnan Street
Jacksonville, FL 32202

Department of Health, Welfare and Bio-Environmental Services
Suite 412

421 West Church Street
Jacksonville, Florida 32202

Waste Water Division

Buckman Sewage Treatment Plant

Buckman Street

Jacksonville, Florida 32202

St. Johns River Water Management District

Jeffrey C. Elledge

Director, Department of Resource Management
P.O. Box 1429

Palatka, Florida 32178-1429

Private Interest Groups

Sierra Club, Power Plant Siting Committee, Florida Chapter

Sierra Club, Jacksonville Chapter

City of Jacksonville Chamber of Commerce

Duval Audubon Society, Inc.

City of Jacksonville Citizens Committee

City of Jacksonville Council

8-8

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CHAPTER 9
BIBLIOGRAPHY

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9.0 BIBLIOGRAPHY

Abolafia, Eliot. February 1989. Competition will Change the Electric Utility
Industry, published by Power Engineering.

AES-CB. 1988. Site Certification Application - The Cedar Bay Cogeneration
Project.

AES-CB. 1989. Responses to First Set of Interrogatories Propounded by the
Staff of the FPSC, Docket No. 881472-EQ, prepared by Frederick M. Bryant and
William J. Peebles of Moore, Williams, Bryant, Peebles & Gautier, P.A.

Babcock & Wilcox. 1978. Steam/Its Generation and Use.

Council of the City of Jacksonville. 1989. Citizen's Committee Report.

EPA, FDER. October 21, 1981. St. Johns River Power Park Draft EIS/SAR,
prepared by EPA, FDER, WAPORA, Inc., and Energy and Environmental Analysis,
Inc .

FCG, 1988. 1989 Planning Hearing-Generation Expansion Planning Studies.
FCG, 1988. 1989 Planning Hearing-20 Year Plan.

FDCA Bureau of State Planning. May 26, 1989. Final Report on the Cedar Bay
Cogeneration Project Power Plant SCA.

FP&L. April 1, 1989. Ten Year Power Plant Site Plan 1989-1998.

FPSC. April 30, 1987. Annual Hearings on Load Forecasts, Generating
Expansion Plans and Cogeneration Prices for Peninsular and Northwest Florida,
Order No. 17480, Docket Nos. 860004-EU and 860004-EU-A.

FPSC. June 30, 1989. Order Granting Determination of Need for the CBCP,

Order No. 21491, Docket No. 881472-EQ.

9-1

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BIBLIOGRAPHY
(Continued)

Jacksonville Planning Department. June 1986. North District Plan.

Singer, Joseph G. 1981. Combustion Fossil Power Systems, published by
Combustion Engineering, Inc.

Smith, Douglas J. March 1989. Independent Power Producers Are Leading the
Way, published by Power Engineering.

Smock, Robert. February 1989. Power Plant Life Extension Trend Takes New
Directions, published by Power Engineering.

9-2

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