United States Region 4 EPA 904/9-81-084
Environmental Protection 345 Courtland Street, NE , moo
... . January 1982
Agency Atlanta, GA 30365
&EPA Environmental
Impact Statement Final
Tampa Electric Company
Big Bend Unit 4
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1 I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA. GEORGIA 3036S _ . w-r
USarsr? Regsoa IV ^
EPA 904/9-81-084 US EtfVKCSM®®31ProCCdlStt Agency
NPDES Application Number: 345 CesrSktad Street
fl 0037044 Masfca, Georgia 30365
Final
Environmental Impact Statement
for
Proposed Issuance of a New Source National
Pollutant Discharge Elimination System Permit
to
Tampa Electric Company
Big Bend Unit 4
Hillsborough County, Florida
Prepared by:
U.S. Environmental Protection Agency
Region IV, Atlanta, Georgia 30365
Cooperating Agency:
U.S. Army Corps of Engineers
Jacksonville District
Jacksonville, Florida 32201
Tampa Electric Company proposes to construct and operate a 417
MW (net) capacity coal-fired electric generating plant at the
existing Big Bend complex adjacent to Hillsborough Bay in
west-central Hillsborough County, Florida. The EIS examines
project alternatives, impacts, and mitigative measures related
to groundwater, air, surface water, ecological, and
socioeconomic and cultural systems.
Comments will be received until MAR ] 5 }gg2
Comments or inquiries should be directed to:
Dario J. Dal Santo
EIS Project Officer
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 881-7458
Approved by
-f
es R. Jeter
'onal Administrator
OtfuTjf fe.
Jan¦ 22, 14g2
Date
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Executive Summary
for
Environmental Impact Statement
Big Bend Unit 4
Tampa Electric Company
( ) Draft
(X) Final
U.S. Environmental Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
1. Type of Action: Administrative (X) Legislative ( )
2. Description of Action
Tampa Electric Company (TECO) is proposing to construct and
operate a 417 MW (net) capacity coal-fired steam electric
generating plant at the existing Big Bend complex in
Hillsborough County, Florida. The EPA Region IV Administrator
has declared the proposed plant to be a new source as defined
by Section 306 of the Clean Water Act. Operation of Big Bend
Unit 4 would 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 the National
Environment Policy Act (NEPA). Consequently, an Environmental
Impact Statement (EIS) has been prepared.
As a public utility TECO is obligated to efficiently provide
adequate electric power to its service area customers. TECO
has conducted an evaluation of its ability to fulfill future
electric power commitments and has determined the addition of a
generating unit is essential to meeting projected future
demands. TECO's forecasted growth rate assumes the Public
Service Commission's conservation goals of reductions in
peakload and energy usage will be achieved. Accounting for
conservation, a reserve margin of 13% would result in the
winter of 1985/1986 without Big Bend Unit 4. Firm commitments
for the purchase of power at an economically competitive rate
have been studied and have been determined not to be cost and
time effective. There is a high probability that the
forecasted load could not be served when outages occur or
maintenance is required.
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Based on testimony and evidence entered during the proceedings
conducted on the need for Big Bend Unit 4, the Florida Public
Service Commission (FPSC) concluded that operation of Unit 4 as
planned (1985) is essential to avoid seriously jeopardizing
future service to TECO customers. The FPSC concluded that the
cost benefit economics of constructing Big Bend Unit 4 have
been demonstrated and the "need" for Big Bend Unit 4 should be
certified.
Additionally, the FPSC stated that evidence suggests
substantial socioeconomic benefits could be realized should the
coal-fired unit displace oil fired generation. Approximately
3.9 million barrels of oil could be displaced annually by Big
Bend Unit 4. This could reduce Florida's dependence on
imported oil by $232 million (1980 dollars).
The proposed Unit 4 and supporting facilities would be located
on approximately 230 acres at TECO's 1675 acre Big Bend complex
adjacent to the Tampa Bay system on the eastern shore of
Hillsborough Bay in west-central Hillsborough County. The City
of Ruskin is approximately 5 miles south of the complex and
Tampa is approximately 12 miles to the north. TECO currently
operates 3 coal-fired generating units totaling 13 36 MW at the
complex. Unit 4 would be constructed directly adjacent to the
existing units and would be operational for approximately 30
years.
Major buildings and structures that would comprise Big Bend
Unit 4 are the turbine hall and boiler complex, electrostatic
precipitators, flue-gas-desulfurization (FGD) facilities, FGD
by-product handling and storage facilities, and condenser
cooling water intake and discharge structures. The unit is
designed to share certain facilities with the existing units
including a stack, transmission towers, coal unloading and
handling facility, and an existing percolation/evaporation
wastewater pond and spray-irrigation field. Stack gases would
be exhausted via the Unit 3 stack which was designed to
accommodate 2 units.
The Unit 4 turbine, boiler, precipitator, limestone storage and
handling, and FGD system would occupy approximately 7 acres.
Approximately 7 additional acres would be committed for the
coal reserve and service facilities associated with Unit 4.
Another 121 acres would be used for an ash settling pond system
(fly-ash and bottom ash) and approximately 97 acres for an FGD
storage/disposal area. The wastewater treatment system
occupies about 40 acres and would not require enlargement.
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Makeup cooling water for Unit 4 would be drawn from the
existing intake canal for Units 1, 2, and 3. These units
currently utilize once-through cooling for waste heat
rejection. The intake structures are equipped with
conventional screens. Unit 4 would be equipped and Unit 3
would be retrofitted with fine mesh screens (0.5 mm) to reduce
the entrainment and impingement losses of marine organisms
associated with withdrawing the tremendous quantities of water
needed for cooling purposes.
Approximately 347 million gallons per day of Hillsborough Bay
water would be required for Unit 4 cooling purposes. An
additional 2.1 million gallons per day of freshwater would be
required for inplant uses. TECO would obtain the freshwater
from the Hillsborough County water system. TECO is presently
studying the feasibility of using non-potable water for inplant
uses. Under provisions of the Site Certification Order, TECO
is required to use non-potable water whenever possible.
Approximately 347 million gallons per day of heated water would
be discharged into the existing discharge canal for Units 1, 2,
and 3. Other wastewaters (inplant waste streams, fly ash
sluicing system blowdown, coal pile runoff, sanitary wastes)
would be directed to the existing wastewater treatment system
and recycled or disposed of by land application. Several
wastes including boiler blowdown, FGD system blowdown, bottom
ash sluicing system blowdown, condenser biocide additions, and
yard drainage would discharge into the discharge canal.
Unit 4 would Durn approximately 950,000 tons of medium-sulfur
bituminous coal per year. Fuel would be delivered by covered
barges using the existing handling facilities. Coal
pretreatment, ooiler design features, and air pollution control
devices would combine to ensure that operation of the proposed
unit complies with applicable air quality regulations.
Particulate matter would be controlled with an electrostatic
precipitator. Sulfur dioxide emissions would be minimized by
coal washing and tail-gas scrubbing using an FGD system. The
formation of nitrogen oxides and carbon monoxide during
combustion would be inhibited by the design and proper
operation of the proposed boiler, furnace, and combustion air
control system.
Bottom ash, pyrites removed from the coal prior to combustion,
economizer ash, and fly ash would oe collected and sluiced to
settling ponds; subsequently, the dewatered waste material
would be disposed of onsite in disposal cells. Fly ash would
be available for sale as future markets allow. High-quality
gypsum (calcium sulfate) generated as a byproduct of the FGD
system would be handled and stored onsite. The storage of this
byproduct would be either short or long term depending on its
marketability. Permanent disposaJ would include onsite
landfilling of tne residual material.
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Transmission facilities to accommodate Unit 4 would be limited
to installation of a new transmission circuit. No offsite
transmission facilities would be required.
3. Major Alternatives Considered
A. Management alternatives (conservation, purchases of power,
reactivating and uprating older units, and joint projects)
Alternatives were evaluated primarily with regard to meeting
TECO's forecasted demands. The FPSC concluded that should
their conservation goals be attained Big Bend Unit 4 would not
be needed from a peninsular standpoint. However, if the goals
were not attained additional peninsular generating capacity may
be needed. For the TECO service area, the FPSC concluded that
Big Bend Unit 4 or an equivalent in generating capacity would
be needed by 1985 despite TECO's achievement of the FPSC's
goals.
TECO does not have any retired units and uprating of existing
units would not produce the amount of generating capacity
needed. The FPSC concluded that firm purchases of power from
other Florida utilities, the Tennessee Valley Authority, and
other out-of-state utilities are not cost or time effective on
the basis of economics considered. Despite this conclusion,
TECO will continue to seek purchase contracts that are
favorable to ratepayers.
B. Energy source alternatives (nuclear, oil, gas, coal,
hydroelectric, solar)
Major consideration was directed toward the state of the art of
these technologies, fuel availability, application to the
siting region, and construction time constraints. The proposed
coal-fired unit was selected as desirable based on
environmental considerations (in conjunction with siting
alternatives), available technology, national fuel use
policies, and engineering, licensing, and construction lead
times. Hydroelectric facilities of the capacity needed lack
the requisite geological conditions in Florida, and the
powerplant and Industrial Fuel Act of 1978 generally prohibits
the use of petroleum as the fuel source for power plants.
Nuclear based generating plants require extremely long lead
times for licensing and construction. Additionally, the Big
Bend complex is located very near the Tampa-St. Petersburg
metropolitan area. Lastly, the nuclear alternative would be
more appropriate for a much larger sized unit than the 417 MW
facility planned.
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C. Siting Alternatives
A detailed siting analysis was performed to identify potential
sites and to assess their environmental and engineering
suitability for a 417 MW coal-fired facility. An initial
screening yielded 13 candidate sites which were further
evaluated on more specific environmental and engineering
criteria. From this process 3 prime sites were identified (Big
Bend, Peace Creek, Highland). Due to the existance of 3 units
at Big Bend and potential reservations regarding water
availability for cooling requirements at the other sites, Big
Bend was selected as the preferred site for the proposed power
plant.
D. Cooling System Alternatives
Cooling alternatives evaluated included once-through cooling
with conventional and fine mesh screens, cooling towers, and
cooling ponds. Cooling water sources considered included
Hillsborough Bay, saline groundwater, freshwater (groundwater
and surface water), and treated municipal wastewater.
Cooling system evaluation was a major issue in the NEPA
process. Prior to commencement of the EIS, EPA Region IV had
found that operation of Units 1, 2, and 3 was entraining
significantly great numbers of eggs and larvae of fish and
shellfish so as to adversely effect the aquatic ecosystem of
Hillsborough Bay. Subsequently, modifications to the
conventional once-through systems (shutting off the dilution
pumps) were instituted to reduce the entrainment impacts.
These impacts were reduced by approximately 36% with no
substantial and unacceptable thermal impact on the aquatic
resources of Hillsborough Bay.
Use of Hillsborough Bay as a source of cooling water in
conjunction with conventional screens on the once-through
cooling intake structure was judged to be an unacceptable
alternative for Unit 4 because the entrainment and impingement
losses for Units 1-4 would be potentially adverse.
EPA's tentative determination is that once-through cooling with
fine mesh screens on the Units 3 and 4 intake structures would
not result in unacceptable adverse entrainment impacts from the
Big Bend complex. EPA tentatively has determined that thermal
impacts to be associated with operation of Units 1-4 would not
cause an unacceptable adverse impact.
The other major cooling system alternative considered was a
cooling tower for Unit 4. With this alternative, entrainment
impacts and thermal impacts would be less severe. However,
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salt drift associated witn operation of the cooling tower could
potentially cause an adverse impact on the agricultural
industry adjacent to the complex. A mechancial draft cooling
tower would cost $40 million more tnan the fine mesn screen
option.
Cooling ponds are not a viable alternative since the required
land is unavailable at the Big Bend complex and at other
sites. Use of freshwater for cooling purposes is .inconsistent
with the water management policies of the Southwest Florida
Water Management District. Freshwater is becoming a critical
resource in Florida and provisions for its distribution and
utilization are structured toward more essential needs.
A potential source of cooling water considered in the analysis
was that of treated municipal wastewater. Because the water
would need to be transported in a pipeline for approximately 6
miles, it was judged to be a less viable alternative
economically and potentially environmentally {cooling towers
would be needed) than the once-through cooling with fine mesn
screens alternative. There would be no entrainment/impingement
impacts associated with this alternative.
E. Wastewater treatment alternatives
Wastewater treatment and discharge systems were evaluated to
assess meeting regulatory requirements and to maximize reuse of
water. The wastewater treatment system currently in operation
at the Big Bend complex is sized to accommodate wastewater from
Unit 4. Alternatives to the neutralization, recycling, land
application system in use include reverse osmosis and
precipitation of metal containing wastes prior to discharge.
However, because the ambient water quality levels in the Tampa
Bay system already exceed water quality standards these were
not considered essential alternatives for protecting the
existing water quality.
F. Air emissions control alternatives
Air emissions control system alternatives were evlauated
considering the state of the art of emission control
technology, environmental impacts, and economics. Major sulfur
dioxide (SO2) control alternatives included coal
beneficiation and several FGD options. Major particulate
control alternatives included wet scrubbers, fabric filters,
mechanical collectors, and an electrostatic precipitator.
Nitrogen oxides (N0X) control alternatives included
application of various combustion technology strategies.
TECO proposes to utilize a limestone scrubbing system to
control SO2# an electrostatic precipitator to control
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particulates, and an off-stoichiometric combustion boiler to
control N0X. A Prevention of Significant Deterioration (PSD)
permit has been issued. Review of this analysis indicates
Federal and State air quality standards would not be violated
by the proposed facility.
G. Residual waste disposal
Alternatives for flyash and FGD sludge focused on marketing the
waste and on onsite disposal. TECO proposes to market the
flyash and FGD byproduct. Provisions have oeen made to dispose
of the residual wastes onsite if suitaole markets become
unavailable.
H. No-action alternative
A no-action alternative was evaluated to consider the effects
and implications of not issuing an NPDES permit to TECO for
Unit 4. Based on the FPSC analysis, construction of Unit 4 is
essential to meeting projected electrical demands in the TECO
service area. Without Unit 4, TECO's reserve capacity after
1985 would be insufficient to ensure adequate generating
capability during outages or scheduled maintenances.
An option available to TECO should an NPDES permit not be
issued is purchase of power. The FPSC has stated that purchase
of power contracts with Florida and out-of-state utilities have
been investigated by TECO. Florida Power Corporation (FPC) and
Florida Power and Light (FPL) have no available capacity from
their certified units. Further, efforts to obtain capacity
from other utilities have been determined not to be cost or
time effective on the basis of the economics considered.
Environmental impacts associated with ground clearing and loss
of land use to the plant facilities and residual disposal areas
would not occur if the facility were not permitted and
constructed. Air emissions in the Tampa Bay area would not
increase as a result of the Big Bend complex. Additionally, an
increase in the thermal impact from the Big Bend complex to the
adjacent aquatic ecosystem would not occur. Loss of aquatic
organisms by entrainment/impingement would not be effected by
the no-action alternative since use of fine mesh screens on
Units 3 and 4 would limit the losses from the 4 unit complex to
approximately those currently observed for Units 1, 2, and 3.
An economic benefit to the Florida peninsular system would also
not be realized if Big Bend Unit 4 were not constructed. The
FPSC has evaluated evidence submitted during the need for power
proceedings and has stated in their Order that based on the
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difference between coal and oil generation costs, an
approximate savings of $232 million (1980 dollars) could be
realized by construction and operation of Unit 4.
X. EPA's Environmentally Preferred Alternative And Recommended
Action
From a purely environmental perspective not constructing Big
Bend Unit 4 would apparently be preferable. Based upon the
FPSC's findings there is apparently sufficient generating
capacity available in the Florida peninsular grid so that
construction of Big Bend Unit 4 would be unnecessary. However,
in order to meet future TECO service area demands TECO would be
required to purchase power from other utilities. Because the
two major Florida utilities (FPC and FPL) have no available
capacity from their certified units, purchase of power from
out-of-state utilities would likely be necessary. The FPSC has
stated that on the basis of the economics considered this
option would not be cost or time effective. Additionally, the
FPSC has stated that substantial socioeconomic benefits could
be realized through displacement of foreign oil if Unit 4 were
constructed.
When the economic findings as stated in the FPSC Order are
considered, other aspects become significant from a permit
issuance standpoint. Consequently, based upon the positive
need for power findings of the FPSC and EPA's evaluation of the
impacts of the proposed project and alternatives, EPA finds the
project alternative proposed by TECO to be environmentally
acceptable.
As defined in preceding paragraphs, this alternative specifies
constructing a 417 MW facility at the Big Bend complex. A
once-through cooling system with fine mesh screens on the Units
3 and 4 intake structures would be employed. Hillsborough Bay
would serve as the source of cooling water. Air emissions
control technology includes electrostatic precipitators for
particulates, flue-gas desulfurization (FGD) for SO2, and
boiler design for NOx.
EPA tentatively proposes to issue an NPDES permit to Tampa
Electric Company for Big Bend Unit 4 as proposed and as
described in the Draft EIS. Several measures to mitigate
environmental impacts of the project (in addition to those
incorporated in the proposed project) have been identified
during the NEPA process and have been included as Part III
conditions to the NPDES permit.
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4. Summary of Major Environmental Impacts of the proposed
Project
The impacts associated with the facility would be a consequence
of the collective interaction of the various system
alternatives (fuel source/ site, cooling system, air emissions
control, residual waste disposal, wastewater treatment)
identified with the proposed project. The primary emphasis of
the assessment of alternatives focused on identifying the
nature and degree of the associated impact and determining
means to minimize adverse impacts.
Construction
The direct effect of constructing Unit 4 and attendant
facilities would be a commitment of 230 acres of land at the
complex. An additional 40 acres would be affected by
construction related activities. This land has been disturbed
during construction of Units 1, 2, and 3 and is presently
characterized as pasture and agricultural land. As a result,
wildlife in these areas would be forced to relocate or more
likely would be lost. This is not considered a major impact
since the area is not a locally important habitat and has been
disturbed in the past.
Jackson Branch which presently traverses the area proposed for
use as bottom and fly-ash disposal ponds would be relocated
east and north of these ponds. Approximately 2400 feet of
channel would be filled and 2900 feet of new channel would be
constructed. Because Jackson Branch is an intermittent stream
minimal adverse impacts are anticipated from this activity.
Approximately 1110 cubic yards of silt and sand would be
dredged from the existing intake and discharge canals during
placement of the intake and discharge structures. Construction
activities would be scheduled to avoid potential impacts to the
manatee. Sedimentation prevention measures (silt barriers)
have been included in the proposed project to reduce impacts to
the aquatic system during dredging operations. The Corps of
Engineers (COE) is preparing to issue a dredge and fill permit
to TECO for construction of the intake and discharge structures
pending completion of the environmental review process.
Restoration of Jackson Branch is also included in the COE's
permitting action.
No point source discharges of construction or site runoff to
waters of the United States is anticipated during the
construction phase. This objective would be achieved through
implementation of an erosion control program. However, there
would be a discharge of dewatering wastes to both the intake
and discharge canals during construction.
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Air quality would be effected by fugitive dust (particulates)
during heavy construction activities. Dust suppression
controls would be utilized to minimize these impacts.
Additional air quality impacts can be expected from vehicle
emissions associated with commuting of the construction force.
The majority (90%) of the peak work force (580 workers) is
expected to be from the Tampa area. Consequently, an
inmigration to the Tampa area of 58 workers and their families
is anticipated. No major impacts on housing or public services
are expected. Increased vehicular traffic in the vicinity of
the complex is anticipated but should not present a traffic
control concern. Acoustics impacts should be minimal and would
be associated primarily with setting of the steam valves.
Operation
Impacts of operations of 6ig Bend 4 would primarily affect air
resources, the groundwater regime, and the aquatic environment
of the Tampa Bay system.
Approximately 347 million gallons per day of Hillsborough Bay
water would be required for Unit 4 cooling purposes. This
would increase the total Big Bend cooling water requirements to
1388 million gallons per day. The entrainment impacts
associated with withdrawing these quantities of bay water are
anticipated to be approximately equal to the impacts currently
associated with operation of Units 1, 2, and 3. TECO tested a
prototype of a fine mesh screened intake structure during a
1980 study program approved by EPA. The results of this
program indicated that fine mesh screens appeared to be 56%
effective in screening eggs and larvae from the source water.
Pish eggs and invertebrate larvae (drum and stone crab)
collected from the fine mesh screen were subject to a low level
of mortality. Since Units 3 & 4 would use fine mesh screens to
reduce entrainment mortality at the Big Bend complex, EPA
concluded that fine mesh screening of the intake structures
would be a viable technology to minimize entrainment effects.
Suggested changes in the design of the intake system and
organism return system would be a means to improve the
screening technology and decrease organism mortality.
The addition of Big Bend 4 would increase the heat load to the
bay by 33% because of the greater volumes of heated water
discharged from the complex. At 100% load (Units 1-4) the
surface area of the Tampa Bay system enclosed by the 1° C
(1.8° F) isotherm at any one time would total 3623 acres
(1449 ha) and that by the 5° C (9° F) isotherm would total
380 acres (150 ha). This represents a 2% increase in the area
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enclosed by the 1° c isotherm and a 54% increase in the area
enclosed by the 5° C isotherm. An enlargement of the benthic
area presently adversely impacted by Units 1, 2, and 3 is
expected. This area would increase from 114 acres (46 ha) to
132 acres (54 ha). EPA tentatively has determined that this
does not represent an unacceptable adverse impact to the
benthos of the Tampa Bay system.
Certain process wastewaters (boiler, bottom ash, and FGD system
blowdowns) would be discharged to the Tampa Bay system.
Because ambient levels of several metals in the bay water and
intake canal exceed Florida Water Quality Standards, discharge
of these wastes would violate the standards. TECO has received
a variance to the standards from the State of Florida.
Analysis has indicated that there would be no analytically
detectable increase in the levels of these metals in the
discharge canal as a result of the operations of Unit 4.
Consequently, no significant impacts are anticipated.
Chlorine is to be used to prevent biofouling of condenser tubes
and would be discharged at maximum levels of 0.2 mg/1
(expressed as total residual oxidants, TRO). Detailed die-away
studies were to be conducted prior to the Final EIS to assure a
0.01 mg/1 TRO level can be achieved in the 6.1 acre discharge
canal. This study was attempted and halted since chlorine
residuals at the point of discharge were undetectable.
Die-away studies will be suspended until chlorine residuals are
detectable in the discharge canal.
Impacts to the groundwater regime could occur in the form of
leachate from the bottom ash and FGD disposal areas, wastewater
pond, spray irrigation field, and coal pile. Primary
constituents of the leachate would include acidity, trace
metals, and dissolved solids. Movement of leachate would be
toward the Tampa Bay system due to natural groundwater flow.
Because of the existing groundwater quality and Tampa Bay water
quality, adverse impacts to the area are expected to be minimal.
Associated with the spray irrigation system, a groundwater
mound would form under the TECO complex. Approximately 0.4
gallons per minute of seepage to the Floridan aquifer is
anticipated.
Principal atmospheric emissions from the facility would be
NOx, S02* and particulates. Dispersion of these emissions
would be assisted by use of a 490 foot tall chimney. A
Prevention of Significant Deterioration (PSD) review has been
conducted for this project. PSD analysis indicated that air
quality changes in the surrounding Class II area and at the
Chassahowitzka National Wilderness Area (a class I area)
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approximately 92 kilometers distant would be within allowable
PSD increment levels. Based on this analysis, state and
federal air quality standards would not be violated.
Negligible effects on local air quality would be anticipated.
Extensive investigations are currently in progress toward
understanding the globally significant acid rain problem.
SO2 and N0X emissions from Unit 4 would potentially
contribute to this phenomenon. The long term effect on acid
rain production is unknown.
No impacts to wetlands, threatened/endangered species,
significant historical/archaeological sites, or agricultural
lands would occur as a result of Big Bend 4.
Operation of Unit 4 would generate considerable residual wastes
that would require disposal. The proposed onsite landfill that
may be utilized represents a long-term commitment of this land
and reduces the potential future uses of the land.
Operational impacts on the socioeconomics of the area are
generally considered minor. Operation of Unit 4 would generate
50 permanent positions in the community. The direct economic
effects would yield approximately $1,400,000 in annual
payroll. The proposed facility is compatible with current area
land-use plans. The existing public, medical, recreational,
and cultural facilities within the surrounding areas would not
be impacted by this facility. No significant noise impacts
would be anticipated.
5. Draft Environmental impact Statement Comments
A Draft Environmental Impact Statement (EIS) was made available
to the Council of Environmental Quality (CEQ) and the public on
July 17, 1981. A public hearing on the Draft EIS was held in
Ruskin, Florida on August 19, 1981.
Several comments on the Draft EIS were raised at the public
hearing and received during the comment period. Major concerns
were expressed in regard to the conservation alternative, acid
rain impacts, impacts to the groundwater, thermal & entrainment
impacts, variances to water quality standards, air quality
impacts, and impacts to the manatee. The comments are
addressed in Chapter 4 to the Final EIS, "Public Participation."
6. Agency Decision
The Big Bend Unit 4 Draft EIS examined the electric generating
strategy proposed by Tampa Electric Company (TECO) and the
associated environmental impacts. The Draft EIS also examined
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alternatives relative to electric generating management,
siting, fuel source, heat dissipation, air emissions control,
and residual waste disposal.
Pursuant to provisions of the Clean Water Act of 1977, EPA
proposes to issue an NPDES permit to Tampa Electric Company for
Big Bend Unit 4. The decision to issue the NPDES permit is
based upon EPA's review of the project and the associated
environmental implications. EPA considered, in the decision
process, the comments raised on the Draft EIS and related
studies by other Federal and State agencies, interest groups,
and concerned citizens. Lastly, no environmental issues have
been identified or raised in the NEPA process that would
necessitate denial of the NPDES permit.
Several measures which would serve to mitigate the impacts of
the proposed project on the surrounding environment were
identified during the environmental review process. These
measures have been made conditions of the NPDES permit and are
outlined below:
o Implement an erosion control and sedimentation program
during construction to reduce potential water quality
degradation from soil laden runoff.
o implement a groundwater monitoring program during
operation to determine whether leachate is
contaminating the groundwater regime and whether more
stringent waste disposal measures are needed.
o Leave undisturbed the mangrove swamp system located
along the southwestern coastal portion of the site.
o Install the fine mesh screens on Units 3 and 4 prior
to Unit 4 pump testing.
o Implement a biological monitoring program to verify
the efficiency of the full-scale fine mesh screen
system and organism return mechanism.
o Close the discharge canal boatramp from November 15 to
March 30 to mitigate potential impacts to the West
Indian manatee (an endangered species) which, because
of heated effluents, is a temporary resident of the
discharge canal during the winter .
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TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY i
Chapter 1 SUMMARY OF DRAFT ENVIRONMENTAL IMPACT STATEMENT 1-1
1.1 PURPOSE AND NEED FOR ACTION 1-1
1.1.1 Need for Action 1-1
1.1.2 Identification of the Applicant 1-1
1.1.3 Need and Purpose for Big Bend Unit 1-2
1.2 ALTERNATIVES, INCLUDING THE PROPOSED ACTION 1-6
1.2.1 No-Action Alternative 1-6
1.2.2 Management Alternatives 1-6
1.2.3 Power Generation Alternatives 1-8
1.2.4 Site Alternatives . 1-9
1.2.5 Applicant's Proposed Project 1-9
1.2.6 Alternative Plant Systems.. 1-11
1.2.6.1 Waste-Heat Rejection Systems 1-11
1.2.6.2 Wastewater Treatment and Disposal Alternatives... 1-16
1.2.6.3 Systems for the Control of Atmospheric
Pollution 1-18
1.2.6.4 Solid Waste Disposal 1-21
1.2.6.5 Transmission Right-of-Way 1-22
1.2.7 EPA's Environmentally Preferred Alternative and
Recommended Action 1-22
1.3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 1-35
1.3.1 Atmosphere 1-35
1.3.1.1 Baseline Conditions at Big Bend 1-35
1.3.1.2 Impacts of Construction Activities 1-35
1.3.1.3 Impacts of Operation 1-36
1.3.1.4 Impacts of Cooling Towers 1-37
1.3.2 Land 1-38
1.3.2.1 Baseline Conditions at Big Bend 1-38
1.3.2.2 Impacts of Construction Activities 1-39
1.3.2.3 Impacts of Operation.... 1-41
1.3.2.4 Impacts of Cooling Towers 1-42
1.3.3 Water 1-43
1.3.3.1 Baseline Conditions at Big Bend 1-43
1.3.3.2 Impacts of Construction 1-50
1.3.3.3 Impacts of Operation 1-52
1.3.3.4 Impacts of Cooling Towers 1-60
1.3.4 Human Factors.... 1-60
1.3.4.1 Demography, Land Use, and Aesthetics 1-60
1.3.4.2 Socioeconomics 1-63
1.3.4.3 Transportation 1-65
1.3.5 Sensitive Species, Habitats, and Areas 1-67
1.3.5.1 Baseline Conditions at Big Bend 1-67
1.3.5.2 Impacts of Construction 1-69
1.3.5.3 Impacts of Operation 1-69
1.3.5.4 Impacts of Cooling Towers 1-70
xv
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TABLE OF CONTENTS (Continued)
Page
1.4 OTHER NEPA CONSIDERATIONS 1-90
1.4.1 Unavoidable Adverse Impacts 1-90
1.4.1.1 Atmospheric Resources 1-90
1.4.1.2 Land Resources 1-90
1.4.1.3 Water 1-91
1.4.1.4 Sensitive Areas 1-91
1.4.2 Relationship of Short-Term Uses of Han's Environment
and Maintenance and Enhancement of Long-Term
Productivity 1-91
1.4.3 Irreversible and Irretrievable Commitments
of Resources 1-91
1.4.4 Conflicts Between the Proposed Action and the
Objectives of Federal, Regional, State, and
Local Plans 1-92
Chapter 2 ERRATA 2-1
Chapter 3 MONITORING PROGRAMS 3-1
3.1 GROUNDWATER MONITORING PROGRAM 3-1
3.2 CONSTRUCTION EROSION AND SEDIMENTATION CONTROL
PROGRAM PLAN 3-3
3.3 FINE MESH SCREEN ORGANISM RETURN SYSTEM 3-4
3.3.1 Engineering Evaluation of
Alternative Locations 3-4
3.3.2 Descriptions of Apollo Beach
Northern Embayment 3-7
Chapter 4 PUBLIC PARTICIPATION 4-1
4.1 WRITTEN COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
AND RESPONSES TO WRITTEN COMMENTS 4-9
4.2 TRANSCRIPT OF PUBLIC HEARING ON DEIS AND RESPONSES TO
TRANSCRIPT COMMENTS 4-199
Chapter 5 LIST OF PREPARERS 5-1
Chapter 6 COORDINATION LIST 6-1
Appendix A NPDES PERMIT AND RATIONALE FOR BIG BEND UNIT 4 A-l
Appendix B NPDES PERMIT AND RATIONALE FOR BIG BEND UNITS 1-3 B-l
Appendix C FINAL ORDER - FLORIDA DEPARTMENT OF ENVIRONMENTAL
REGULATION - VARIANCE TO STATE WATER QUALITY STANDARDS.... C-l
xv i
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LIST OF TABLES
Table Page
1-1 Ten-year forecasts of capacity and demand during sum-
mer and winter peaks for Tampa Electric Company .1-4
1-2 Water use at the Big Bend Station. 1-25
1-3 Comparison of the major environmental impacts of the
principal alternatives for waste-heat rejection 1-28
1-4 Costs of using once-through cooling with fine-mesh
screens and a mechanical-draft cooling tower at the
Big Bend Station . 1-29
1-5 Solid wastes produced by Big Bend Unit 4.................... 1-29
1-6 National and State of Florida ambient-air-quality stand-
ards applicable to the proposed site, Hillsborough
County, Florida 1-71
1-7 Federal and State of Florida prevention of significant
deterioration allowable increments 1-72
1-8 Maximum air-quality impacts at the Big Bend site with
Unit 4 operating.... 1-72
1-9 FDER prevention of significant deterioration maximum
increment consumption at the Big Bend site................ 1-73
1-10 Water-quality data for Hillsborough Bay, Florida 1-74
1-11 Intake cooling-water quality at Big Bend Station 1-75
1-12 Water quality of site ground water and suggested EPA
standards 1-76
1-13 Sumnary of water quality data for the Floridan aquifer...... 1-77
1-14 Comparison of temperatures of the effluent from Unit 4
at the outfall with seasonal ambient water temperatures
for the once-through cooling alternative 1-78
1-15 Continuous discharge stream water quality 1-79
1-16 Big Bend Unit 4 discharge-water quality following treat-
ment to meet State and Federal effluent limitations....... 1-81
1-17 Big Bend 4 discharge-water quality following treatment
to meet State and Federal effluent limitations and
reverse-osmosis treatment of the blowdown streams......... 1-82
1-18 Checklist of special status species.. 1-83
3-53R Checklist of special status species 3-166a
3-1 Potential alternative organism return locations 3-6
xv ii
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LIST OF FIGURES
Figure Page
1-1 Service area, Tampa Electric Company 1-5
1-2 Preferred sites .... 1-30
1-3 General location of the Big Bend site 1-31
1-4 Plot plan, Big Bend Station 1-32
1-5 Plant water balance for Big Bend Station 1-33
1-6 Once-through cooling system for Big Bend Units 1-4 1-34
1-7 Annual wind roses for Tampa and MacDill 1-85
1-8 Vegetation cover types of Big Bend Station. 1-86
1-9 Annual salt-deposition rate for a mechanical-draft
cooling tower at Big Bend Station 1-87
1-10 Isothermal contour map for three generating units
operating at 100 percent load with no dilution
pumps, Big Bend Station 1-88
1-11 Isothermal contour map for four Big Bend units
operating at 100 percent load with no dilution
pumps 1-89
2-4R Plot plan, Big Bend Station. 2-23R
2-5R Plant water balance for Big Bend Station 2-24R
3-1 Piezometric surface map of the surficial
aquifer, March 1973, Big Bend Station, Tampa
Electric Company. . 3-2
3-2 Potential organism release locations 3-5
xviii
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Chapter 1
SUMMARY OF DRAFT ENVIRONMENTAL IMPACT STATEMENT
1.1 PURPOSE AND NEED FOR ACTION
1.1.1 NEED FOR ACTION
The action as defined for this document is EPA's issuance of a National
Pollutant Discharge Elimination System (NPDES) permit to Tampa Electric
Company for the proposed Big Bend Unit 4.
Under provisions of the Federal Water Pollution Control Act, as amended
by the Clean Water Act of 1977 (33 U.S.C. 1251 et seq.), the Tampa Electric
Company has applied to the United States Environmental Protection Agency
(EPA) for an NPDES permit for the proposed power plant. In compliance
with its responsibility under the National Environmental Policy Act (NEPA)
of 1969, the EPA has determined that the issuance of an NPDES permit for
the proposed project would constitute a major Federal action significantly
affecting the quality of the human environment and is subject to the pro-
visions of NEPA. Prior to a decision on and issuance of the permit, Coun-
cil of Environmental Quality (CEQ) and EPA procedures for implementing
NEPA (40 CFR 1500-1508 and 40 CFR 6, respectively) require an environmental
impact statement that identifies impacts of the proposed action and alter-
natives on the natural and human environments.
The draft environmental impact statement (DEIS) and draft NPDES permit
have been prepared to provide Federal, State, and local agencies and the
concerned public with sufficient and comprehensible information on the
proposed project, the alternatives to the project, and the EPA's proposed
action.
1.1.2 IDENTIFICATION OF THE APPLICANT
The Applicant is the Tampa Electric Company (TECO), with headquarters at
702 North Franklin Street, Tampa, Florida. The company is principally
engaged in the generation and sale of electricity. The Applicant is a
member of the Florida Electric Power Coordinating Group (FCG) and actively
participates in the coordination, planning, and operation of the Peninsular
Florida Electric System.
TECO serves an area of nearly 1900 square miles on the central west coast of
Florida, including all of Hillsborough County and parts of Pasco, Pinellas,
and Polk Counties. TECO serves approximately 316,000 customers; TECO's
service area is shown in Figure 1-1.
TECO produces electricity in three wholly owned power plants located on
or near the eastern shores of Tampa Bay. The units in these plants have
a generation capability mix of approximately 65 percent coal, 29 percent
No. 6 low-sulfur oil, and 6 percent No. 2 low-sulfur oil. The energy pro-
duced from these plants has a generation mix of approximately 80 percent
coal, 19 percent No. 6 fuel oil, and 1 percent No. 2 low-sulfur oil.
1-1
-------
Hookers Point Station is the oldest of TECO's three power plants. It is
located just southeast of the Tampa business district on Hookers Point,
fronting the Seddon Ship Channel.
Gannon Station is 6 miles south of Tampa. The six units at this site orig-
inally burned coal. To comply with environmental requirements, the first
four units were converted to No. 6 low-sulfur oil in 1975 and 1976. Units
5 and 6 burn low-sulfur coal. An additional 14-megawatt gas turbine, which
burns No. 2 low-sulfur oil, is also located at Gannon Station. The Appli-
cant plans to convert the first four units back to coal beginning in 1983.
Big Bend, located 10 miles south of Tampa, is TECO's newest power plant.
The three existing units burn coal. One 14-megawatt and two 65-megawatt
gas turbines, which burn No. 2 low-sulfur oil, are located just north of
Big Bend Station.
Presently, TECO's three power plants have a total net generating capability
of 2495 megawatts.
1.1.3 NEED AND PURPOSE FOR BIG BEND UNIT
The Applicant's charter is to provide electric power reliably, at a reasonable
price, and to maintain the system in a manner consistent with those objectives.
The proposed facility is not intended for other purposes, such as the production
of steam for resale.
TECO is an active participant in the FCG as well as the FCG System Planning
Committee. The 1979 Annual Peninsular Florida Generation Reliability Study
indicates that, for the period of 1979 through 1988, the loss-of-load proba-
bility for peninsular Florida will range from 0.03 day per year (1979) to
0.18 day per year (1988), compared to the desired value of 0.1 day per
year. This estimate includes currently planned additions.
Based on the projected load growth, the net summer and winter peak demands
are forecast to increase by about 64 and 86 megawatts per year, respectively,
averaged over the period 1981-1989. ThiB need can best be met by (1) the
addition of Big Bend Unit 4 to existing baseload capacity in 1985, (2) the
realization of a projected joint generating facility in 1989, and (3) pro-
visional power purchases.
A unit power contract involving Big Bend Unit 4 has been negotiated between
TECO and another utility for the period 1985 through 1987. The other utility
will receive shares of Unit 4 generating capacity according to the following
schedule established by TECO: approximately 70 percent in 1985, 50 percent
in 1986, and 25 percent in 1987.
TECO has an obligation to contribute its fair share of the generating addi-
tions to maintain the reliability of the peninsular Florida system. Major
objectives are to maximize the benefits of joint operation, to minimize
the effects of generation outages associated with the functioning of a
large electric-power-supply system, and to contribute a fair share to the
ensurance of system reliability. TECO's fair share is determined through
an evaluation of its reliance upon the peninsular Florida generation and
interconnection system. According to TECO's site certification application,
1-2
-------
the 1978-1979 total system winter peak demand for TECO is 10.5 percent of
the total system peak of peninsular Florida.
Table 1-1 shows the effect on TECO's system reserves of postponement of
the in-service date of Big Bend Unit 4; the firm-load winter reserves for
1985-1986 would drop to 9 percent from the projected 26 percent.
Findings of the Florida Public Service Commission (FPSC) indicate that
the achievement of energy-conservation goals would make the addition of
the Big Bend Unit 4 to the peninsular Florida system unnecessary. If the
goals are not achieved, additional generating capacity may be required.
The FPSC has stated, however, that additional capacity will be needed in
the TECO service area despite attainment by the utility of its conservation
goals. The FPSC has further stated that delay in constructing Big Bend
Unit 4 could jeopardize future service to TECO customers.
Alternatives to this project (e.g., purchase of power and the reactivating
and uprating of units) are discussed in Section 1.2.
A further consideration in the need for Big Bend Unit 4 is the displacement
of foreign oil for the generation of electricity. Based on evidence presented
during the need for power proceedings, the FPSC order indicated that operation
of Big Bend Unit 4 would contribute approximately $232 million (1980 dollars)
toward reducing Florida's dependence on foreign oil.
1-3
-------
Table 1-1. Ten-year forecasts of capacity and demand during
summer and winter peaks for Tampa Electric Company3
Capacity with Big Bend 4
Total
Firm
Total
Margin with
Margin without
Peak
installed
capacity
available
Big Bend 4
Big Bend 4
demand
capacity
import
capacity
Percent
Percent
Year
(MW)
(MW)
(MW)
(MW)
MW
of peak
MW
of peak
Summer
forecast
1980
1860
2495
2495
635
34
1981
1920
2520
—
2520
600
31
—
—
1982
1984
2520
—
2520
536
27
—
—
1983
2064
2520
350
2870
806
39
—
—
1984
2124
2520
350
2870
746
35
—
—
1985
2188
2937
58
2995
807
37
390
18
1986
2247
2937
142
3079
832
37
415
18
1987
2309
2937
246
3183
878
38
457
20
1988
2372
2937
350
3287
915
39
498
21
1989
2439
3337
—
3337
898
37
481
20
Winter
forecast
1980-81
2047
2495
2495
448
22
*
1981-82
2122
2520
—
2520
398
19
—
—
1982-83
2199
2520
—
2520
321
15
—
—
1983-84
2284
2520
350
2870
586
26
—
—
1984-85
2362
2520
350
2870
508
22
—
—
1985-86
2448
2937
142
3079
631
26
214
9
1986-87
2537
2937
246
3183
646
25
229
9
1987-88
2630
2937
350
3287
657
25
240
9
1988-89
2726
2937
350
3287
561
21
144
5
1989-90
2825
3337
—
3337
512
18
95
3
Abbreviation: MW = megawatts.
aStatus as of December 31, 1979.
Note: Capacity changes must be made by November 30 to be considered in effect at the time of
tin riatir pUK, Ml m/mtt vtlm in mt Mfintti,
-------
I
Ln
o 10 20 30 Miles
O »C=J——: I
Figure 1-1. Service area, Tampa Electric Company.
Osceola Co
Pasco Co,
Haines City
Lakeland,
Winter Haven
Clearwater
Tampa
Bay/.
Fort Meade
Hillsborough Co.
'rrrrrrrrrrrrrrm
Hardee Co
Gulf of Mexico
Polk Co.
-®-1
rV
I Avon Park
Pinellas Co
~ A
\{\
St. Petersburg
Manatee
Co
-------
1.2 ALTERNATIVES, INCLUDING THE PROPOSED ACTION
1.2.1 NO-ACTION ALTERNATIVE (Non-issuance of the NPDES Permit)
Information needed to evaluate the no-action alternative to the proposed
project has been presented in the discussion of the need for action
(Section 1.1).
The number of customers relying on TECO for electric power is projected to
increase from about 316,000 in 1980 to about 429,000 in 1990. Total sales
are projected to increase from 10,141 gigawatt-hours in 1979 to 11,891 in
1985 and to 12,980 in 1989. While industrial consumption is currently about
23 percent higher than residential consumption (1979), the difference is
expected to decrease to 18 percent by 1985 and to only 10 percent by 1989.
TECO's reserve, with Big Bend 4 operating, is projected to be in the 20 to
25 percent range in the late 1980s. Without this unit, the reserve would
drop to 3 to 9 percent despite the importation of several hundred megawatts
of capacity during the same time span (Table 1-1). The guideline for reserve
capacity is usually about 25 to 30 percent for an individual system such as
TECO's. The expected consequence of the lowered reserve capacity is the loss
of a reliable supply of electric power.
Should TECO experience a capacity deficiency, it would implement a plan of
priority assignments to reduce the load and ensure system stability. This
is a short-term plan, however, and cannot be relied on in lieu of long-term
system planning. The plan, beginning with curtailment of the interruptible
load, has frequently been implemented in varying degrees. The latter phases
of the plan, involving curtailment of firm load, have been required only
on very rare occasions, as on January 18, 1977, when it snowed in Tampa.
Should an NPDES permit not be issued, TECO could investigate possibilities
for purchasing power from other utilities to meet projected capacity needs.
The consequences of no action would be mainly socioeconomic. The lack of
reliable power supplies might, for example, discourage the development of
the economic sectors needed to support the rapidly growing population, thus
affecting the availability of employment in the area. As for the physical
environment, there would be no additional impacts on local air, land, or
water resources other than those attributable to the operation of Units 1,
2, and 3.
1.2.2 MANAGEMENT ALTERNATIVES
Several other alternatives to the construction of Big Bend Unit 4 have been
examined. These alternatives include the purchase of power from other utili-
ties, joint projects with adjacent facilities, the uprating of older generat-
ing units, the reactivation of retired facilities, the construction of a
smaller facility, and conservation.
The purchase of power—assuming it were available—from other Florida util-
ities would be the same as the no-action alternative, considering its poten-
tial effect on the availability of energy in Florida. The purchase of
power from outside Florida—if adequate transmission facilities existed—
would provide a temporary solution to the need for power by the State.
1-6
-------
While the purchase of power can be a short-term solution, it is becoming
more difficult to obtain the necessary approval for the construction of
additional capacity for long-term sales to other utilities. The Applicant
has not actively pursued long-term power purchases outside Florida because
of questions relating to the transmission line/intertie capability to sustain
long-tem loads.
TECO is pursuing joint ownership for future generation expansion. To meet
future baseload requirements, coal and nuclear power will continue to be
reviewed to determine the most economical and feasible means of generation
expansion. By using economy of scale, two or more utilities may benefit
from joint ownership. Several jointly owned units are currently planned
by other Florida utilities for online service in the mid-1980s. TECO pres-
ently has three full interchange agreements with the Florida Power and Light
Company, the Florida Power Corporation, and the City of Lakeland. TECO also
has economy interchange agreements with the Fort Pierce Utilities Authority,
the Orlando Utilities Commission, and Vero Beach Municipal Utilities, and
will participate in other economy interchange transactions whenever practical
and possible. TECO has negotiated a contract with Florida Power and Light
Company for the sale of power from Big Bend Unit 4 on a decreasing annual
basis for the first 3 years of operation.
The Florida Public Service Commission, pursuant to the Florida Power Plant
Siting Act (Florida Statutes, Chapter 403), prepared a final report to the
Florida Department of Environmental Regulation as to the present and future
need for the proposed Big Bend Unit 4. In its deliberations on the issue
of need, the Commission took into consideration the conservation goals for
Florida electric power utilities established by its Order 9634, issued on
November 13, 1980. The Commission concluded that, if its conservation
goals are achieved, Big Bend Unit 4 may not be needed from the standpoint
of the peninsular system's capacity. However, the Commission also concluded
that it appears that the proposed unit is needed for TECO's system, whether
or not TECO achieves the conservation goals allocated to it by the Commission.
While the uprating of older units can be a solution to a utility's capacity
needs, this is generally true only for larger utilities, where the necessary
increase in capacity is only a small fraction of the entire system's capa-
bility. This is not the case for TECO. TECO will require approximately
15 percent in additional capacity during the mid-1980s, and it is not pos-
sible to uprate the existing units to achieve this additional capacity.
In addition, TECO will not be derating any units that could be retained
online.
TECO does not have any retired units that could be activated as an alterna-
tive to Big Bend Unit 4, and it does not plan on any retirements during the
time span of concern.
TECO has considered a reduction in size of the planned coal-fired unit and,
alternatively, the construction of a smaller unit such as a gas turbine.
While a smaller unit can be constructed more quickly, the cost per megawatt
is usually very high. The availability of alternative oil or gas fuels is
also a questionable factor. An additional consideration is the new-source
performance standard of the EPA, which requires the scrubbing of all new
1-7
-------
boiler emissions and documentation of the historical performance of flue-
gas-scrubbing equipment. Excess flue-gas-scrubber capacity may be neces-
sary to maintain the baseload capability of the proposed generating unit
in the event of a scrubber malfunction requiring shutdown for maintenance.
The additional scrubber costs may have a smaller per-unit energy impact in
larger plants.
1.2.3 POWER GENERATION ALTERNATIVES
In evaluating alternatives, coal was determined to be the most feasible
energy source. Other potential sources considered were nuclear fission,
oil, natural gas, municipal solid waste, solar-thermal power, wind, and
biomass.
Coal is the most feasible energy alternative for Unit 4 for several reasons.
Three coal-fired electricity-generating units are presently operating at
the Big Bend site. Thus, coal-handling and transportation facilities are
already in place and will require minimal expansion to accommodate the new
unit. Finally, the Applicant has established an adequate supply of coal
for the next 10 years. The most obvious disadvantage of this fuel is that
all new coal-fired boilers will require flue-gas cleaning to reduce emissions.
The introduction of cleaning equipment at other facilities has resulted in
reduced reliability, problems in solid-waste disposal, and increased capital
and operating costs.
The lead time required for the licensing, design, and construction of a
nuclear-fuel-generating facility is presently close to 10 years. As a
result of the Three Mile Island incident, the schedule for the licensing
of proposed new units is largely conjectural. The proximity of Big Bend
to the more populated areas of Hillsborough County also militates against
locating a nuclear plant at that site. Furthermore, the cooling-water re-
quirements of nuclear power plants are considerably greater than those of
coal-fired units. For these reasons, nuclear fuel is not considered a feasi-
ble alternative for Unit 4.
The Power Plant and Industrial Fuel Use Act of 1978 (PL 95-620) generally
prohibits the use of residual fuel oil and natural gas as boiler fuels in
base load-generating facilities, and the U.S. Department of Energy is encour-
aging the conversion of existing units to coal use. Thus, oil and natural
gas cannot reasonably be considered for use in new, large-scale electricity-
generating facilities.
Several other alternative energy sources were considered for power gener-
ation, but none were deemed feasible for fulfilling TECO's requirements.
The use of municipal solid waste as an alternative energy source is limited
by stringent air quality standards and by the lack of a viable collection
and preparation system. There are too many unknown factors related to the
technical and economic feasibility and the environmental impacts of solar-
thermal power production for this approach to be considered a reasonable
alternative to the proposed generating facility. Likewise, the use of
windpower for conventional baseload-generating facilities has not been
adequately demonstrated. Several methods of producing fuel from biomass
are currently being tested with a view to making use in the future of the
large quantities of municipal and agricultural organic wastes available.
1-8
-------
1.2.4 SITE ALTERNATIVES
The site-selection process for Big Bend Unit 4 consisted of three stages.
In the first stage, area-'wide screening for general environmental suitabil-
ity was conducted. The purpose was to identify favorable and restricted
areas in Hillsborough, Polk, Pasco, Pinellas, Manatee, and Hardee Counties.
The favorable areas were then screened for conformity with certain require-
ments, and 13 candidate sites were identified. In the second stage, the
candidate sites were evaluated and ranked for suitability according to the
environmental criteria and the site requirements. This analysis identified
the three most favorable sites. The third stage consisted of three phases:
(l)a sensitivity analysis of the evaluation methods to determine how pos-
sible changes in the subjective evaluations would affect the recommendation
of the most favorable site; (2) a detailed engineering cost analysis to estab-
lish a ranking of the three prime sites; and (3) a detailed licensability
analysis of the most favorable site to verify the existence or nonexistence
of fatal flaws.
The siting analysis indicates that, of the three most favorable sites, Site
8A (Big Bend) is significantly more suitable than the other sites. Sites 7
(Peace Creek), 2 (Highland), and 3A (Strip Mine) were the most suitable
alternatives. Figure 1-2 shows the 13 sites identified following the first
stage of the analysis.
A sensitivity analysis was performed to determine the effects of variations
in input data on the site-suitability scores and on the overall rankings.
The results of this analysis show that Big Bend is the preferred site, with
Peace Creek and Highland ranked second and third, respectively.
A detailed analysis was also performed to determine the costs of construct-
ing and operating power plants at each of the preferred sites. Estimates
of capital costs, recurrent (annual) costs, and total annual costs above the
base case were developed. This cost analysis indicated that Big Bend is
the preferred site for the proposed facility.
The Big Bend site is also preferred on grounds of water availability. At
the most suitable alternative sites, Peace Creek and Highland, only limited
amounts of water are available.
In addition to best meeting the various criteria of the siting study, the
Big Bend site has two other important advantages: it is closest to the major
population centers to be served by the new unit, and it is part of a site
already committed to power generation. The construction of Unit 4 at Big
Bend would thus entail very little disturbance of previously undisturbed
environmental areas.
1.2.5 APPLICANT'S PROPOSED PROJECT
TECO is proposing to expand the existing three-unit, coal-fired electricity-
generating facilities at Big Bend Station with the addition of a fourth coal-
fired unit. The site of the proposed unit is an area of 521 acres of dredged
fill land and 558 acres of upland on the southeastern shore of Hillsborough
1-9
-------
Bay, a part of Tampa Bay. The site is approximately 5 miles north of the
town of Ruskin (Figure 1-3) and occupies approximately 1675 acres, of which
800 acres are presently in use.
Big Bend Unit 4 will have a net capacity of 417 megawatts, giving Big Bend^
Station a net generating capacity of 1503 megawatts. The commercia opera
tion of Unit 4 is scheduled for March 1985.
The site plan, which includes the proposed additions for Unit 4, is presented
in Figure 1-4. The unit is designed to share certain structures and facili-
ties with the existing units, including transmission towers, coal unloading
and handling equipment, and a wastewater-treatment system. The turDine room
and boiler complex will be an extension of existing structures.^ o us ion
gases will be exhausted via the stack for Unit 3, which was designed to accom-
modate two units.
Main plant structures will occupy approximately 7 acres, the coal reserve
and service facilities approximately 7 acres, the ash-settling Pon ®y® em
approximately 121 acres, and the FGD byproduct storage and disposa area
approximately 97 acres. An existing percolation and evaporation waste-wa er
pond with a spray-irrigation field occupies approximately 40 acres an wi
not require enlargement.
It is proposed that Unit 4 utilize a once-through condenser cooling system ^
with makeup from Hillsborough Bay. The system will be similar to a P*es
ently used for Units 1, 2, and 3, except that the intake will e equippe
with fine-mesh screens (aperture: 0.5 millimeter) to reduce t e en rainmen
and impingement of marine organisms. Operation of Unit 4 will require appro
mately 347 million gallons of cooling water per day and will xncreas® tae
total cooling-water requirements of Big Bend Station to 1 10 8
per day. The maximum design water temperature rise with Unit opera ing
will be 16.8°F.
Unit 4 will burn approximately 950,000 tons of medium-sulfur bituminous coal^
per year. The coal will be delivered by the existing transport metho s (cov
ered barges) and will be handled by the existing facilities. The existing
coal-storage field will be modified to accommodate the additional coal
stored for use in Unit 4.
The freshwater needs of the present facility amount to an average of 1.1 mil-
lion gallons per day, which is supplied from the South/Central Hillsborough
County water system. The operation of Unit 4 will require an addition 1
2.1 million gallons per day from this source. The plant water balance for
the proposed unit is shown in Figure 1-5 and itemized in Table I"2* ^
FGD system will use most (1.1 million gallons per day) of this freshwater,
and most of the remainder will be used in the bottom-ash system (0.5 million
gallons per day) and in the fly-ash, economizer-ash, and pyrites sluicing
systems (0.05 million gallons per day).
The existing plant wastewater-treatment system consists of an in-plant col-
lection and transportation system, wastewater-treatment ponds, and spray-
irrigation or recycling systems. This wastewater system will receive the
following wastes associated with operation of Unit 4j all freshwater inplant
waste streams; blowdown from the fly—ash, economizer—ash, and pyrites sluicing
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systems; sanitary wastes; and runoff from the coal storage pile. These wastes
will be collected and transported to retention and treatment ponds and then,
after treatment, will be recycled for plant use or disposed of by spraying on
land.
Liquid wastes from Unit 4 that will be discharged into Tampa Bay waters in-
clude condenser biocide additions, boiler blowdown, blowdown from the bottom-
ash sluice system, and treated chloride bleed from the FGD system, all of
which will be discharged into the discharge canal via the circulating-water
discharge line, as well as roof and yard drainage, which will discharge into
the intake and discharge canals.
It is estimated that solid-waste generation resulting from Unit 4 operation
will total approximately 357,380 tons per year. Bottom ash, pyrites removed
from the coal before combustion, economizer ash, and fly ash will be collected
and sluiced to settling ponds; subsequently, the dewatered waste material will
be disposed of in onsite disposal cells. Fly ash will be available for sale
as future markets allow. High-quality gypsum (calcium sulfate) generated
as byproduct of the operation of the Unit 4 FGD system will be handled and
stored on the site. The storage of this gypsum will be either short- or long-
term, depending on its marketability. Permanent disposal will include onsite
land-filling of the residual material.
Coal pretreatment, boiler design features, and air-pollution-control devices
will combine to ensure that the operation of the proposed unit complies with
applicable air quality regulations. Particulate matter will be controlled
with an electrostatic precipitator, which will be installed at the exit of
the air preheater. Sulfur dioxide emissions will be minimized by a combina-
tion of procedures, including coal washing and tail-gas scrubbing in an FGD
system. The formation of nitrogen oxides and carbon monoxide during combus-
tion will be inhibited by the design and proper operation of the proposed
boiler, furnace, and combustion air control system and by the operating pro-
cedures for this equipment.
The expansion of transmission facilities to accommodate Unit 4 will be limited
to the installation of a new transmission circuit, which will use the existing
towers and transmission routes. The addition of the circuit will not require
additional land, additional clearing of vegetation, or changes in topography.
1.2.6 ALTERNATIVE PLANT SYSTEMS
1.2.6.1 Waste-Heat-Rejection Systems
One of the more critical decisions with respect to minimizing the potential
environmental impacts of Unit 4 is the selection of the waste-heat-rejection
system. There are two types of systems that are feasible for application in
the present project: once-through cooling and closed-cycle cooling (cooling
towers). Several different design alternatives of each type of system were
examined carefully from the point of view of impacts on the site and its en-
virons. Table 1-3 is a comparison of the principal potential impacts of each
major alternative considered.
TECO originally proposed that Big Bend Unit 4 use a once-through cooling
system with conventional intake screens. After reviewing TECO's Section 316
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Demonstration, the EPA concluded that the entrainment and impingement losses
for Units 1-4 are potentially adverse. The EPA determined that the use of
fine-mesh screens for Big Bend Units 3 and 4 would limit entrainment effects
to approximately the current impacts of Units 1, 2, and 3.
Once-Through Cooling with Fine-Mesh Screens on Units 3 and 4, No Dilution
(Applicant's Proposed System)
By this alternative, Unit 4 will have a once-through cooling system, and a
fine-mesh screen (aperture: 0.5 millimeter) will surround the 9.5 millimeter
(3/8-inch) mesh traveling screens of Units 3 and 4. Unit 4 will have a con-
denser independent of Units 1, 2, and 3, and it will be cooled by water with-
drawn from Hillsborough Bay via the existing intake channel. The intake
structure will be in common with Unit 3. Figure 1-6 illustrates the cooling
water system of the existing three units and that proposed for Unit 4.
After passing through the Unit 4 condenser, the water will exit (NPDES Serial
No. 008) to the existing discharge channel and combine with water discharged
from Units 1, 2, and 3 (NPDES Serial Nos. 001, 003, and 004). The mixture
will flow westerly, returning to Hillsborough Bay.
Unit 4 will draw approximately 537 cubic feet per second of circulating water
from the existing intake channel. Approach velocities to the 0.5-millimeter-
mesh screens will be about 0.5 foot per second. The average water velocity
immediately in front of the 9.5-millimeter screenwell will be about 1.45 feet
per second.
As a result of EPA concern regarding the number of organisms entrained at Big
Bend Station Units 1, 2, and 3, the Applicant initiated a multiphase evalua-
tion of alternative intake technologies to identify potential design alterna-
tives for the Unit 4 intake structure. The results of this evaluation indi-
cated that a fine-mesh screening system (specifically, a modified, dual-flow
traveling screen) could reduce the loss of entrained organisms at Big Bend
Station. Consequently, more detailed studies to further evaluate the fine-
mesh-screen concept were conducted during 1980.
The test results show that a fine-mesh screen system could reduce the entrain-
ment losses at Big Bend by returning viable meroplankton organisms to the bay
system. As a basis for ecological and engineering evaluations of the poten-
tial effectiveness of fine-mesh screening at Big Bend Station, a conceptual
design for such a system was developed. The number and size of the fine-
mesh screens have been preliminarily determined on the basis of a standard
screen-face velocity (approach velocity) of 0.5 foot per second at 0.0 mean
low water. Low- and high-pressure sprays (5 to 10 pounds per square inch
and 40 to 60 pounds per square inch, respectively) will wash organisms and
debris into separate troughs.
All troughs will manifold into a common sluiceway, and the combined flow will
pass through a debris trap and a 4-inch-mesh screen. The flow will carry
organisms and debris to a release point north of the intake channel via an
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18-inch pipe. The organism-return pipe will be sized to achieve a transport
velocity of less than 5 feet per second. The length of the return flume will
range from 1500 to 4700 feet, depending on the exact routing and location of
discharge.*
As a part of the conceptual design evaluation, cost estimates were developed
for installing fine-mesh screens at Big Bend Units 3 and 4. Costs were also
estimated for a duplicate system that could be installed on Units 1 and 2 if
further reduction in entrainment were required. The cost of the organism-
return pipe, which would be shared by all four units if equipped with fine-
mesh screens, was included only in the cost for Units 3 and 4. These costs
were compared to the differential costs (costs over and above the costs of a
conventional once-through system) of a closed-cycle cooling system. Table 1-4
provides a summary of this cost comparison.
In the once-through cooling system, pipes from the Unit 4 condenser will
connect to a 9-foot-diameter pipe leading the water to the discharge struc-
ture. The Unit 4 discharge structure will resemble those for Units 1, 2,
and 3. The warm circulating water from Unit 4 will also exit to the dis-
charge channel. Flow from the Unit 4 discharge structure will combine with
the discharge water from the three existing units and move westerly through
the channel to the point of discharge to Tampa Bay.
Big Bend Units 1, 2, and 3 are equipped with one chlorinator, to which Unit 4
will be connected. Liquid chlorine will be fed to the Unit 4 cooling water
at a similar rate and in the same manner that it is being fed to the existing
units. Only one unit at a time will be chlorinated. It is currently pro-
posed that total residual oxidant (TRO) levels at the discharge be limited to
0.2 milligram per liter.
The use of a fine-mesh screening system on the intakes of Units 3 and 4 will
limit organism entrainment to approximately the rates presently occurring
with the use of conventional 9.5-millimeter (3/8-inch) mesh screens on
Units 1-3 without thermal-dilution cooling. Organisms removed from the cool-
ing water by the fine-mesh screens will not experience the effects of pass-
age through the condenser-cooling system, but instead will be exposed to the
effects of impingement on the screen and subsequent return, via a sluiceway,
to local waters.
Once-Through Cooling with Fine-Mesh Screens on Units 1-4, No Dilution
This alternative consists of equipping existing Units 1, 2, and 3 and new
Unit 4 with the fine-mesh screen system. However, not all of the potential
engineering problems with this alternative have been resolved. With this al-
ternative, organism-entrainment levels would be further reduced below those
occurring with a conventional once-through system. Economic costs for this
alternative are detailed in Table 1-4.
*This discussion is summarized from the Draft EIS. See Chapter 3 (Section 3.3)
of this FEIS for the most recent analyses.
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Once-Through Cooling with Conventional Screens, No Dilution
With this alternative, cooling water for Unit 4 is drawn from the intake chan-
nel and passes through a debris fence and conventional (9.5-mm-mesh) travel-
ing screens to the screenwell. From the screenwell it is pumped through the
condenser and then flows to the discharge point south of the unit. The design
temperature rise of the water passing through the Unit 4 condenser is 16.8°F
at 100 percent load.
By this alternative, as opposed to the use of a fine-mesh screen system en-
trained organisms would be subjected to the effects of passage through the
condenser-cooling system. Moreover, organisms impinged on the screens would
not be returned to local waters, but would be disposed of as waste.
The EPA stated in the Finding and Determination for the Section 316 Demonstra-
tion for Units 1-4 that TECO's analysis failed to demonstrate that conventional
once-through cooling would adequately minimize entrainment impacts, it was
also estimated that the addition of a fourth conventional once-through cooline
system to the existing facilities could increase the current impingement ef-
fects of Unit8 1, 2, and 3 by approximately 33 percent. The EPA concluded
that entrainment and impingement losses for four Big Bend units using conven-
tional screens are potentially adverse.
Once-Through Cooling with Dilution
This option is the same as the once—through alternatives described above, ex-
cept for the addition of a flow of ambient unheated water into the discharge
canal in order to reduce the temperature of the effluent before it enters
Hillsborough Bay. Water at ambient temperature is withdrawn by pumps from
the intake side of the site and released into the discharge stream.
A dilution system for Units 1-4 could utilize either one or two pumps. With
all four units at full load, the dilution effect from one pump would reduce
the temperature rise from intake to discharge from about 16.8°F to about
11.8°F. A reduction to about 9.2°F would be achieved with two dilution pumps
in operation. Mixing with ambient water would decrease the temperature of the
thermal plume in the discharge canal. The overall plume would have a larger
areal extent, but the area within the highest isotherms would be smaller, an
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Closed-Cycle Cooline Systems
TECO commissioned a study to determine the preferred type of closed—cycle
heat-rejection system for Big Bend Unit 4. The closed-cycle systems consid-
ered in the study were a natural-draft wet-cooling tower and a concrete, cir-
cular mechanical-draft wet-cooling tower with multiple fans.
The mechanical-draft cooling-tower system was selected as the preferred closed-
cycle system primarily on the basis of economics. The net present value of
the capital and performance costs associated with the natural-draft closed-
cycle system was estimated to be approximately $22 million more than those
of the mechanical-draft system.
The natural-draft tower does not offer any significant environmental advan-
tages that would outweigh its greater cost. The natural-draft tower was
judged to be slightly preferable to the mechanical-draft in terms of salt-
drift impacts, ground-fogging potential, and noise, but less desirable with
respect to aesthetic impacts.
TECO's preferred design for the Big Bend Unit 4 mechanical-draft wet-cooling
tower would use saltwater makeup from Tampa Bay. Because the tower cools
by evaporating some of the water flowing through, makeup water must be added
to replace it. Salt or minerals in the makeup tend to concentrate in the
cooling-tower water since evaporation removes only pure water, leaving other
constituents behind. To control their concentration, a portion of the water
circulating in the tower system is discharged as "blowdown," and the makeup
is increased by a corresponding amount. In the case of the Big Bend Unit 4
tower, makeup (from Tampa Bay) would have an average salinity of 28 parts
per thousand, and the design salinity in the water circulating in the tower
would be 1.5 times that level, or 42 parts per thousand. Makeup water would
be taken through a makeup-intake structure located either adjacent to the
Unit 3 circulating-water intake or in the discharge canal. Blowdown would
be discharged (NPDES Serial No. 008) to the discharge canal.
During operation of the cooling tower, droplets of circulating water (drift)
are entrained in the air flowing through the tower and are exhausted in the
air stream leaving the top of the tower. The drift contains dissolved solids
that are present in the circulating water—primarily salt in the case of Big
Bend Unit 4. Drift eventually is deposited on soils, vegetation, structures,
etc., with potentially harmful effects. Cooling towers are equipped with
drift eliminators, but, while they are capable of substantially reducing
drift, they cannot eliminate it altogether.
Important environmental considerations relative to the use of this alternative
heat-rejection system include (1) the effects of salt drift on local air, land,
and equipment; (2) the increased fogging potential and noise levels; (3) the
potential for aesthetic impacts; (4) potential impacts on surface-water
quality due to the discharge of tower blowdown; (5) the very small impact of
impingement and entrainment; and (6) the small thermal discharge to Hillsbor-
ough Bay.
A closed-cycle system for Big Bend Unit 4 will be substantially more expensive
than the proposed once-through system. In terms of capital cost, the mechanical-
draft system represents an incremental cost of about $26 million at the time
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of commercial operation. There is also a performance penalty of approximately
$1.9 million per year. The net present value of the annual capital and per-
formance costs of the mechanical-draft system is about $6.1 million more than
that of the once-through system.
Treated-wastewater was considered as an alternative source of makeup for a
mechanical-draft wet-cooling tower for Unit 4. With this alternative, the
reduced content of dissolved solids in the wastewater would allow for a
higher concentration factor (ratio of solids in the circulating water to
solids in the makeup water) and higher drift rates. Blowdown could be re-
duced by about 10 times. Less elaborate and hence less costly drift elim-
inators would be required. The required makeup rate would be approximately
4300 gallons per minute (approximately 6.2 million gallons per day) with
the unit operating at maximum output. There would be no impingement or en-
trainment of aquatic organisms with this alternative since no water would
be withdrawn from Hillsborough Bay.
There is no supply of treated wastewater within several miles of the Big Bend
site. Thus, a large pipeline several miles in length would be required to
transport the makeup water to the site. The cost of such a pipeline makes
this system an expensive alternative.
Other alternative sources of cooling tower makeup water that were considered
include brackish and fresh ground water.
Preliminary indications are that brackish makeup water that meets and exceeds
quality* quantity, and environmental requirements can probably be supplied
from an approximate depth of 2000 to 3000 feet. If the need for a brackish
water cooling-tower makeup source is indicated, an additional study program
will be required. This program would consist of (1) the development of a
computer model to simulate well-field and aquifer responses for the 35-year
life of the station and (2) a field-testing program that will include the
construction of a production test well and several test wells. On completion
of this study, conclusions can be drawn as to the feasibility of using the
brackish-water source, and the environmental effects of pumping the aquifer
can be predicted.
Freshwater resources in the Big Bend area are limited to ground water that is
used for agricultural activities. The quantities of water needed as makeup
for a closed-cycle system would place a great burden on the local ground-water
resources. For this reason, investigative efforts have concentrated on find-
ing a feasible source of sewage effluent.
1.2.6.2 Wastewater Treatment and Disposal Alternatives
The liquid wastes generated by the operation of Big Bend Unit 4 will consist
of the following:
• Water-treatment and condensate-polisher wastes
• Wastes from equipment washing and boiler chemical cleaning
• Floor and equipment drainage
• Boiler blowdown
• Blowdown from the service-water cooling-tower system
• Blowdown from the bottom—ash—sluice system
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• Wastes from fly-ash, economizer-ash, and pyrites sluicing
• FGD system chloride bleed stream
• Runoff from the coal-storage pile
• Sanitary wastes
All of these wastes are freshwater wastes. Unlike Units 1, 2, and 3, Unit 4
will not generate any saltwater waste streams.
Big Bend Unit 4 will use three separate systems for the treatment and dis-
posal of liquid wastes: a wastewater-treatment system, a sewage-treatment
plant for sanitary wastes, and a system for treating the FGD chloride bleed
stream.
A wastewater-treatment system was installed at Big Bend during 1976 and
1977 to comply with the provisions of the NFDES permit issued by the EPA
on March 31, 1976. The system now serves Units 1, 2, and 3 but is of ade-
quate capacity to receive the wastes from the proposed Unit 4.
This system will be used for all in-plant waste streams produced by the pro-
posed Unit 4 other than boiler blowdown, blowdown from the bottom-ash sluice
system, and the FGD chloride bleed stream, all of which will be discharged to
local surface waters. The wastes destined for the wastewater-treatment system
will be captured by the in-plant collection system. This system consists of a
network of sumps and piping throughout the plant area that receives wastewater
from washing operations, equipment drains, etc., and conveys it to the main
transfer sump. The mixture of wastewaters is then conveyed to the wastewater-
treatment ponds. Any wastes that are discharged to the wastewater-treatment
system will be recycled or disposed of by evaporation/percolation or spray
irrigation, with no point-source discharge to waters of the United States.
Wastewater from all station sanitary fixtures is collected and conveyed to
an existing package-sewage-treatment plant. This plant, which uses the
extended-aeration aerobic-digestion process, was sized to accommodate future
enlargements of the station. Effluent from the treatment plant is disin-
fected with chlorine and then discharged into the plant wastewater-treatment
system for ultimate disposal through spray irrigation.
Boiler blowdown (NPDES Serial No. 009) and blowdown from the bottom-ash sluice
system (NPDES Serial No. 010) will be discharged, untreated, to the Unit 4
condenser-cooling-water discharge pipe (NPDES Serial No. 008), which will dis-
charge into the station discharge canal.
The FGD-system chloride-bleed stream will be treated for total suspended
solids, pH, and oil and grease in a liquid-waste treatment system. After
treatment, the flow (NPDES Serial No. 011) will be discharged into the Unit 4
condenser-cooling-water-discharge pipe (NPDES Serial No. 008), which dis-
charges into the station discharge canal. Sludge from the treatment process
will be disposed of in the gypsum storage and disposal area.
Two alternative methods of treating the FGD-system chloride-bleed stream,
boiler blowdown, and bottom-ash blowdown to meet water-quality criteria be-
fore mixing have been evaluated: the use of reverse osmosis and the treat-
ment of the boiler and bottom-ash blowdowns in the treatment system provided
for the FGD-chloride-bleed stream.
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TECO's analysis indicates Chat it would not be practicable to use reverse
osmosis to treat the indicated waste streams. The boiler and bottom-ash
blowdown streams are projected to have total-dissolved-solids concentrations
at or below 500 parts per million. These concentrations are considered to
be below acceptable levels for the optimum operation of a reverse-osmosis
system. In the FGD chloride bleed stream, the total-dissolved-solids con-
centration is projected to be approximately 108,000 parts per million. The
treatment of such a concentration would require reverse-osmosis membranes
capable of withstanding pressures in excess of 2000 pounds per square inch,
which is beyond the capability of standard reverse-osmosis systems. More-
over, the chemical constituents of the FGD bleed stream could cause scaling
of the membrane. Analysis indicates that reverse-osmosis treatment would
not produce a measurable improvement in the water quality of the effluent
at the point of discharge. Accordingly, TECO believes that the estimated
$1.8 million cost of the system would not be justified, since no detectable
benefit in water quality would result.
The FGD-bleed-stream-treatment system is designed for the removal of sus-
pended solids and for the adjustment of pH to meet effluent standards. This
system would have to be upgraded to handle the flows from all three blowdown
streams. The cost for redesigning the system is estimated by TECO at about
$1.2 million.
The Applicant states that treatment of the boiler and bottom-ash blowdowns
in the FGD-bleed-stream-treatment system is not practicable for the follow-
ing reasons:
1. Boiler blowdown will be in compliance with effluent limitations.
2. Bottom—ash blowdown will meet effluent limitations, and the pH
of the bottom ash will comply with effluent limitations without
treatment.
1.2.6.3 Systems for the Control of Atmospheric Pollution
Several alternatives for atmospheric pollution control systems were examined.
Alternatives for the Control of Sulfur Dioxide Emissions
Several systems were considered for the control of sulfur dioxide emissions:
lime/limestone-slurry scrubbing with coal washing—the system that is proposed
by TECO; the dual-alkali FGD system; the Wellman-Lord process; and a number
of as yet unproved techniques, including chemical coal cleaning, coal treat-
ment by solvent refining, fluidized-bed combustion, and the magnesium oxide
process.
As proposed, sulfur dioxide emissions from Big Bend Unit 4 will be minimized
through a combination of coal washing and tail-gas cleaning using a forced-
oxidation, double-loop FGD system. Based on as-mined coal-sulfur content,
a 90 percent overall reduction in sulfur dioxide emissions is expected, and
this will ensure compliance with the revised new-source performance standard
(NSPS). It is further expected that, with raw-coal sulfur levels equal to
or more than 3 pounds per million Btu (but no more than 6 pounds per million
Btu), the overall sulfur dioxide-removal requirement of 90 percent will be
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achieved through a combination of approximately 25 percent removal (in terms
of pounds per million Btu) in washing, 5 percent retention in the ash from
fired sulfur, and 86 percent removal in flue-gas cleaning. As a byproduct
of this process, gypsum, suitable for the manufacture of wallboard, will
be produced. TECO is planning to market the gypsum for that purpose. An
onsite area of approximately 97 acres has been designated for storage and/or
disposal of all gypsum.
Using the proposed control system, the sulfur dioxide emissions from Unit 4
will range from 2592 to 5184 pounds per hour as long as the sulfur content
of the coal ranges from 3 to 6 pounds, as proposed by TECO. These emissions
will be in conformity with the State of Florida ambient-air-quality standards
(AAQS).
There are several features of the dual-alkali FGD system that make it economi-
cally unattractive for Big Bend Unit 4. The overall cost of reagents for
the system is much greater. The reagents are not readily available, and the
waste solids produced have a high proportion of calcium sulfite and signifi-
cant quantities of highly soluble sodium salts in their surface moisture.
The waste would probably require stabilization to prevent leaching of the
salts at the disposal site and to prevent calcium sulfite from exerting a
chemical oxygen demand. Such developments would significantly increase the
disposal costs.
The Wellman-Lord process is a regenerable process that produces a marketable
end product, either elemental sulfur or sulfuric acid, and thereby minimizes
waste disposal. Nevertheless, there are several features of this system that
make it unattractive. It is energy intensive, has higher capital and operat-
ing costs, high water requirements and energy penalties, a complete plant and
a tank-farm facility are required for the production of the byproduct sulfuric
acid, and the Applicant must enter into sulfuric acid sales. Preliminary in-
quiries have revealed little interest in the purchase of such sulfuric acid.
Alternatives for the Control of Particulate Emissions
The alternatives considered for the control of particulate-matter emissions
from Big Bend Unit 4 were electrostatic precipitation, which is the system
proposed by TECO, and fabric-filter particulate-collection systems.
Emissions of particulate matter from the boiler of Big Bend Unit 4 will be
controlled by an electrostatic precipitator (ESP). The collection efficiency
will be a minimum of 99.7 percent, and the maximum concentration of total
suspended solids emitted by Unit 4 will be 3.7 micrograms per cubic meter.
These emissions are below the level of significant impact, conform to the
State of Florida AAQS and match the applicable NSPS for electric utility
steam-generating units. Like the fly ash from existing Big Bend units, fly
ash collected in Unit 4 will be marketed by TECO. Provision will be made
for the onsite disposal of fly ash should the market for the ash cease to
exist.
Fabric-filter particulate-collection equipment is regarded as the only tech-
nically feasible alternative to electrostatic precipitators capable of ade-
quately limiting emissions from Big Bend Unit 4. It has been commercially
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demonstrated on both utility and industrial boilers and has achieved emission
reductions of substantially more than 99 percent.
The selection of an ESP rather than a fabric-filter installation is based
primarily on the demonstrated availability and reliability of the ESP at
similar facilities firing high-sulfur coals. Moreover, ESPs and baghouses
are considered to be capable of comparable particulate-collection efficien-
cies for boilers firing coals under consideration for Unit 4. Generally,
the fabric filter is capable of providing slightly higher removal efficien-
cies. However, the ESP is much more cost-effective for application with
medium- to high-sulfur coal like that to be used at Big Bend Unit 4. in
addition, the fabric-filter equipment would operate with a higher energy
loss due to gas-pressure drop, and its operating and maintenance costs would
be significantly higher for this application.
Alternatives for the Control of Nitrogen Oxide Emissions
Generally, required reductions in nitrogen oxide emissions are possible
through alternative combustion techniques, which include water or steam in-
jection; flue-gas recirculation; and over-fire air, also known as two—stage
combustion. The proposed combustion-type control technology for nitrogen
oxide emissions from the Unit 4 boiler is considered the only available sys-
tem capable of meeting the NSPS and thus it is the Applicant's proposed
system.
The emission of nitrogen oxide from the combustion system will be minimized
by the design of the burners and boiler to be provided by the boiler manu-
facturer, Combustion Engineering, Inc. (CE). The balance—draft boiler with
a tangentially fired furnace to be used at Unit 4 has a demonstrated capa-
bility of limiting nitrogen oxide formation from the firing of bituminous
coal to 0.6 pound per million Btu as nitrogen dioxide. This meets the appli-
cable NSPS. The nitrogen oxide emissions from Unit 4 will be 2598 pounds
per hour. The maximum annual nitrogen dioxide concentration will be
0.5 microgram per cubic meter. This is in compliance with the State of
Florida AAQS.
Control of Carbon Monoxide Emissions
Carbon monoxide emissions from the Unit 4 boiler will be minimized by opera-
tion at excess-air levels sufficient to achieve essentially complete combustion
to carbon dioxide and by the appropriate design of the combustion-air control
system. This system is judged the best available control technology for car-
bon monoxide because no alternative means of controlling this pollutant are
currently available or under development.
The estimated emissions of carbon monoxide from Unit 4 are 2457 pounds per
hour. The maximum 3-hour concentration is predicted to be less than 8 micro-
grams per cubic meter, which is far below the level of significant impact.
The emissions of carbon monoxide are not controlled by Federal or State
regulations.
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1.2.6.4 Solid Waste Disposal
The operation of the proposed Big Bend Unit 4 will produce several kinds of
solid waste: gypsum from the FGD system, pyrites removed from coal before
combustion, and ash from coal combustion (Table 1-5). In addition, Unit 4
will generate economizer ash and waste solids from water treatment.
Described below is TECO's proposed solid-waste disposal scheme.
Bottom ash will be collected in a water-filled hopper and sluiced to either
of two primary settling ponds formed by earthen dikes. Most of the bottom
ash will settle in the primary settling ponds. Once these ponds are filled,
the ash will be hydraulically dredged to a final disposal cell developed as
the need for disposal volume arises.
At times when it may be impossible to market Unit 4 fly ash, an ash-disposal
pond will be used. The solids will be sluiced from the plant to either one
of two lined primary settling ponds. When the ponds reach the point at which
they must be cleaned, a final earthen-diked disposal cell will be constructed
and lined. The ash will be hydraulically dredged to the disposal cell.
Economizer ash and pyrites removed from the coal before combustion will also
be disposed of in the fly-ash disposal system.
The waste produced by the FGD system will consist mainly of gypsum, which
will be handled and stored in an area south of the Unit 4 ash pond. The
gypsum is considered to have greater market potential than any other possi-
ble byproduct of an FGD system. It has been successfully used in the pro-
duction of wallboard, in cement manufacturing as a set retarder, and in
agriculture as a soil additive.
TECO has developed a multiphase plan for gypsum storage and disposal. The
purpose of this plan is (1) to provide gypsum storage during periods of low
gypsum demand and (2) to provide time for the establishment of a long-range
plan for the disposal of gypsum should a permanent market fail to materialize.
The plans provide for either permanent disposal or short-term storage of
gypsum, as required. The use of comparatively small disposal areas will
allow good control of rainfall runoff and of housekeeping operations if sub-
stantial quantities of gypsum should accumulate.
If substantial gypsum storage proves necessary, a landfill will be created
using a heaped-fill configuration. This technique is deemed to be the most
adequate in view of the geologic and topographic characteristics of the site.
In order to contain the gypsum, berms will be constructed around the entire
area. These berms will be designed to withstand a 100-year flood and storm
surge. Stormwater falling within the bermed area will be directed to tem-
porary stormwater storage in that area. It will then be allowed to percolate
into the ground or evaporate.
Disposal schemes other than that selected for Big Bend Unit 4 include (l) off-
site disposal and (2) commercial application without throwaway disposal. The
lining of the gypsum storage and disposal area was also evaluated.
1-21
-------
For purposes of offsite disposal, the ash and scrubber sludge would have to
be transported great distances to either a coal mine, a limestone quarry, a
phosphate mine, an impoundment, or a landfill. The cost of such transport is
a major deterrent to offsite disposal. The two waste products have significant
commercial potential, and for that reason, throwaway disposal may be deemed
inappropriate.
The alternative of lining gypsum storage and disposal areas was evaluated in
a 20-month study conducted by the Electric Power Research Institute at a
power plant in northern Florida. The results of that study indicated that
the disposal in an unlined area of gypsum produced by an FGD system similar
to that proposed for Big Bend Unit 4 had no substantial adverse impact on
the quality of water in the surficial or Floridan aquifers in the vicinity
of the disposal site. It is estimated that it would cost $1.1 million to
install a flexible, synthetic liner in the gypsum storage and disposal area.
1.2.6.5 Transmission Right-of-Way
One 230-kilovolt circuit with a length of 2970 feet (9/16 mile) will con-
nect Big Bend Unit 4 to the existing Big Bend substation. Electric power
generated by the unit will enter the existing TECO transmission system at
that point. The new transmission circuit will use existing towers and the
existing transmission route between the plant and the substation.
1.2.7 EPA'S ENVIRONMENTALLY PREFERRED ALTERNATIVE AND RECOMMENDED ACTION
From an environmental perspective, not constructing Big Bend Unit 4 would
apparently be preferable. Based upon the FPSC's findings, there is appar-
ently sufficient generating capacity available to the Florida peninsular
grid so that construction of Big Bend Unit 4 would be unnecessary. However,
in order to meet future TECO service area demands TECO would be required to
purchase power from other utilities. Because the two major Florida utilities
(FPC and FPL) have no available capacity from their certified units, purchase
of power from out-of-state utilities would likely be necessary. The FPSC has
stated that on the basis of the economics considered this option would not
be cost or time effective. Furthermore, the FPSC has stated that substantial
socioeconomic benefits could be realized by construction of Unit 4 through
displacement of foreign oil.
When the economic findings as stated in the FPSC Order (Appendix G of the
DEIS) are considered, other aspects become significant from a permit issuance
standpoint.
Based upon the positive need for power findings of the FPSC and EPA's evalua-
tion of the impacts of the proposed project and alternatives, EPA finds the
project alternative proposed by TECO to be environmentally acceptable.
The alternative preferred by the EPA is therefore as follows!
Management: Big Bend Unit 4
Fuel: Coal
Site: Big Bend
1-22
-------
Waste heat rejection: Once-through cooling with fine-mesh screens on
Units 3 and 4 (cooling water to be drawn from Hillsborough Bay)
Air emissions control;
Particulates—electrostatic precipitators
Sulfur dioxide—lime/limestone scrubbing with coal washing
Nitrogen oxide—boiler design
Residual solid waste disposal: Sale of fly ash and gypsum; provisions
for onsite storage if necessary
Analyses demonstrate that the ambient levels of several metals (arsenic,
cadmium, chromium, copper, mercury, nickel, lead, selenium) in Hillsborough
Bay and in the intake canal may violate State of Florida water-quality stand-
ards. Consequently, the discharge of certain effluents (boiler, bottom-ash,
and FGD blowdowns) from Unit 4 as proposed would violate the water-quality
standards. Control systems such as reverse osmosis and the chemical treatment
of blowdowns are available to reduce the levels of metals in the effluents.
While changes in the ambient water quality resulting from these discharges,
treated or untreated, are mathematically predictable, they would be undetect-
able at the levels projected. TECO has received a variance from the Florida
water-quality standards from the Florida Department of Environmental Regulation.
The Conditions of Certification approved by the Governor and Cabinet state
that TECO will explore the practicability of treating the boiler blowdown
in the FGD system treatment system when there is capacity in the system to
accomodate that blowdown. EPA considers this to be an acceptable approach
to the discharge of plant effluents.
TECO's proposed method for the disposal of fly ash and gypsum is to sell
these resources as construction materials. However, should the state of
the economy shift, their sale may be impossible and onsite disposal may be
required. TECO proposes to dispose of bottom ash at the site. The onsite
disposal of these materials will cause leachate to enter the surficial ground
water during periods of storm runoff. The fly-ash area will be lined with
an impermeable material to prevent leachate contamination. The bottom-ash
and gypsum areas will be unlined. Although the EPA considers the lining of
these areas to be an environmentally preferable alternative, preliminary
studies indicate that the leachability of these materials, particularly the
gypsum, will be minimal. One condition of the NPDES permit is the develop-
ment and implementation of an acceptable ground-water-monitoring program
to preclude adverse impacts to the ground-water regime.
The assessment of environmental impacts associated with TECO's proposed proj-
ect took into account mitigative measures that were not included as part
of TECO's project proposal. Specifically EPA recommends that—
1. A ground-water-monitoring program be implemented before operation
so that, should any significant contamination of ground water be
demonstrated, corrective measures could be instituted to ensure
no further significant leaching.
1-23
-------
2. An erosion and sedimentation control program be implemented to
prevent silt and soil-laden runoff during Unit 4 construction.
3. The mangrove area along the southwestern shoreline of the site be
left undisturbed and protected as specified in TECO's proposed project.
4. A program to reduce impacts on the manatee, an endangered species,
be implemented as recommended by the U.S. Fish and Wildlife Service
5. Fine-mesh screens for Units 3 and 4 and the organism return system
be installed and operational before Unit 4 pump testing.
6. A biological monitoring program be implemented so that the impacts
of Unit 4 in conjunction with Units 1-3 on the benthos of the Tampa
Bay System and the survivability of organisms during operation of
the full-scale fine-mesh-screens and organism return mechanism can
be assessed.
The EPA tentatively proposes to issue an NPDES permit to TECO for Big Bend
Unit 4. A draft of the proposed permit is presented in Appendix A. The
project authorized by the permit is that described as TECO's proposed proj-
ect in this document. This project will incorporate all measures identi-
fied as conditions of the permit (Part 111 conditions).
1-24
-------
Table 1-2.
Water use at
: Big Bend
Station (Sheet 1 of 3)
(Thousands
of gallons
per day)
Line
Average
Maximum
b
number Use
use
use
Nature
Duration
Frequency
A
Activated-carbon bed influent
145.2
145.2
C
—
—
B
Activated-carbon bed effluent
144.9
144.9
C
—
—
C
Activated-carbon bed backwash
0.3
0.3
I
—
1
per week
D
Anion/cation bed effluent
115.0
115.0
C
—
—
E
Anion/cation bed backwash
29.9
29.9
I
—
1
every 30 hours
F
Mixed-resin bed effluent
(boiler makeup)
114.2
114.2
c
—
—
G
Mixed-resin bed backwash
0.8
0.8
I
—
1
every 27 days
H
Neutralization/equalization
effluent backwash
38.7
38.7
c
I
Condensate-polisher backwash
makeup
8.0
8.0
I
—
1
every 4 days
J
Condensate-polisher backwash
8.0
8.0
I
—
1
every 4 days
K
Boiler blowdown
43.2
43.2
c
—
—
L
Boiler chemical cleaning waste
0.9
0.9
I
2 hours per stage
1
every 2 years
M
Vent losses
15.0
15.0
c
—
—
N
Soot-blowing losses
47.1
47.1
I
—
—
0
Service cooling-water makeup
210.0
210.0
c
—
—
P
Service cooling-water
evaporation losses
138.0
138.0
c
—
—
Q
Service cooling-tower blowdown
72.0
72.0
c
—
—
R
High- and low-pressure fire
protection system
Nil
Nil
I
—
—
S
Domestic service water
1.3
1.3
I
—
—
T
Sewage-treatment plant effluent
1.3
1.3
1
—
—
U
Hose connection
0.1
2.9
I
4 hours
1
every 4 weeks
V
Pump seals
10.8
10.8
c
—
—
w
Clinker/grinder seals
1.3
5.4
1
2 hours
3 per day
X
Coal equipment wash
2.1
2.1
I
16 hours
4
per year
Y
FGD system makeup
1,123.2
1,123.2
c
—
—
Note: See abbreviations and footnotes at end of table.
-------
Table 1-2. Water use at Big Bend Station (Sheet 2 of 3)
(Thousands of gallons per day)
Line
number Use
Average
use
Maximum
use
Nature
Duration
Frequency
Z
FGD slurry (85% water)
1,741.0
1,741.0
C
—
—
AA
FGD evaporation losses
989.3
989.3
C
—
—
BB
Hydroclone effluent to filter
316.8
316.8
C
—
—
CC
Vacuum-filter sludge (20%
water)
74.9
74.9
C
—
—
DD
Vacuum-filter recycle
241.9
241.9
C
—
—
EE
Hydroclone recycle
1,424.4
1,424.4
C
—
—
FF
Recycle to FGD system
1,607.1
1,607.1
C
—
—
GG
FGD system wash
66.6
133.3
I
—
—
HH
Service-water effluent
21.2
21.2
I
—
—
II
Wastewater-treatment system
recycle
21.2
21.2
I
—
—
JJ
Air-preheater wash
9.4
9.4
I
8 hours
1
every 3 months
KK
Precipitator wash
5.3
5.3
I
80 hours
3
per year
LL
Economizer wash
0.3
0.3
I
4 hours
3
per year
MM
Sparging system
4.6
4.6
I
24 hours
3
per year
NN
External boiler wash
1.6
1.6
I
24 hours
2
per year
00
Fly-ash pond blowdown
72.0
72.0
I
—
—
PP
Wastewater-treatment system
percolation losses
30.0
30.0
c
—
—
QQ
Spray-irrigation system
169.5
183.4
I
RR
Construction runoff
0
0
I
SS
Condenser cooling water
347,072.0
347,072.0
c
TT
FGD system blowdown
59.0
59.0
c
- ~
UU
Bottom-ash pond makeup
505.0
505.0
c
W
Condenser cooling effluent
347,072.0
347,072.0
c
WW
Coal-storage runoff
—
—
I
«
— —
XX
Bottom-ash recycle
1,825.0
1,825.0
c
--
YY
Fly-ash sluice-water makeup
72.0
72.0
I
™ —
"
Note: See abbreviations and footnotes at end of table.
-------
Table 1-2.
Water use at
(Thousands
Big Bend
of gallons
Station (Sheet 3 of 3)
per day)
Line
Average
Maximum
b
number Use
use
use
Nature Duration
Frequency
AAA
Bottom-ash sluice
2,300.0
2,300.0
I
—
BBB
Bottom-ash system evaporation
losses
30.0
30.0
C
—
CCC
Fly-ash sluice
1,440.0
1,440.0
I
—
DDD
Fly-ash recycle
1,368.0
1,368.0
I
—
EEE
Bottom-ash pond percolation
losses
360.0
360.0
C
—
FFF
Bottom-ash pond blowdown
115.0
115.0
C
—
GGG
Construction water uses
NA
NA
I
—
HHH
Domestic water uses
NA
NA
I
—
III
Condenser cooling-water
makeup
15,408.0
15,408.0
c
—
JJJ
Condenser cooling-tower
evaporation losses
5,184.0
5,184.0
c
—
KKK
Condenser cooling-tower
blowdown
10,224.0
10,224.0
r
w
—
Abbreviations:
C = continuous.
I = intermittent.
FGD = flue-gas-desulfurization.
NA = not available.
aSee Figure 1-5.
^Key: C = continuous; 1 = intermittent.
-------
Table 1-3. Comparison of the major environmental impacts of the
principal alternatives for waste-heat rejection
Alternative
Thermal impacts
Entrairment impacts
Impingement impacts Salt drift impacts
Fogging
Land requirements
Once-through cooling for
Units 1-4, conventional
screens, no dilution
Area of the warmest
portions of the
plume larger than
that of any other
alternative
Large numbers of organ-
isms entrained (approx-
imately 33% more than
present entrainment with
Units 1-3)
Impingement rates
about 33X higher
than present levels
with Units 1-3
None Occasional fogging
of water areas into
which discharge
plume flows; some
increase in area
over existing situ-
ation with Units 1-3
Considered as base
condition for this
analytical table
2.
Same as Alternative
but with dilution
1, Overall plume larger
than that of any
other alternative,
but area of warmest
temperatures smaller
than that of Alter-
native 1
More organisms entrained
than with any other
alternative because of
additional organisms
introduced into thermal
plume by dilution
Approximately the
same as Alter-
native 1
About the same as
Alternative 1
Commitment of small
additional area
adjacent to exist-
ing dilution system
for third pump
3. Once-through cooling for Same as Alter-
I
KJ
00
Units 1-4, fine-mesh
screens on Units 3 and
4, no dilution
Same as Alternative 3,
but with dilution
native I
Same as Alter-
native 2
Numbers of organisms
entrained about the
same as for existing
Units 1-3
Entrainnent rate some-
what lower than with
Alternative 2
Impingement rates
somewhat below
present levels
Approximately the
same as Alter-
native 3
None
None
Same as Alter-
native 1
Same as Alter-
native 2
Commitment of some
small additional
area in intake
canal
Commitments as for
Alternatives 2 and
3 combined
Once-through cooling
for Units 1-4, fine-
mesh screens on all
units, no dilution
Seme as Alter-
native 1
Lowest entrainment rate
of all once-through
alternatives; rate below
that of existing system
on Units 1-3
Lowest impingement
rate of any of the
once-through
alternatives
Same as Alter-
native I
Commitments of
small area intake
canal beyond that
needed for Alter-
native 3
Same as Alternative 5,
but with dilution
Saltwater cooling
towers for Unit 4
Same as Alter-
native 2
Very small increase
in size of thermal
plume over present
situation with
Units 1-3
Numbers entrained Approximately the None Same as Alter-
greater than for Alter- same as AlteT- native 2
native 5 because of ad- native 5
ditional organisms intro-
duced into thermal plume
by dilution flow
Very small increase in Very small increase Largest quantities Some fogging in
numbers entrained over
present situation with
Units 1-3
in numbers impinged
over present situ-
ation with
Units 1-3
of salt released
into air than with
any cooling-tower
alternative
considered
area of the tower;
no increase in
sea fogging over
present situation
with Units 1-3
Commitments as for
Alternatives 2 and
5 combined
Large commitment of
additional land
areas to the south
of discharge canal
near mangrove area
8. Brackish-water cooling
towers for Unit 4
Same as Alter-
native 7
Somewhat smaller
quantities of salt
released than in
Alternative 7
Same as Alter-
native 7
Same as Alter-
native 7
9. Freshwater cooling
towers for Unit 4
Same as Alter-
native 7
None
None
Lowest quantities
of salt released
of any cooling-
toweT alternative
considered
Same as Alter-
native 7
Same as Alter-
native 7
-------
Table 1-4. Costs of using once-through cooling with fine-mesh screens
and a mechanical-draft cooling tower at Big Bend Station
(Thousands of dollars)
Costs
Once-through cooling
with fine-mesh screens
Units 3 and 4 Units 1 and 2 Cooling tower
Capital $ 8,690
Revenue requirements
Operating cost penalties 520
Operation and maintenance 1,005
$6460
520
1005
$31,373
19,256
1,173
Total
$10,215
$79 8 5
$51,802
Table 1-5. Solid wastes produced by
Big Bend Unit 4
Quantity
Waste material (tons/yr)a
Bottom ash^ 25,680
Pyritesc 19,000
Fly ashd 102,700
Gypsum 210,000
aBased on the use of coal with an ash
content of 13.5 percent and on a 28-year
average capacity factor of 52.5 7 percent.
^Bottom ash assumed to be 20 percent of
ash content.
cPyrites assumed to be 2 percent of coal.
^Fly ash assumed to be 80 percent of ash
content.
1-29
-------
Orange Co.
Gulf of Mexico
Glades Co.
• J1/, CD | V I
_[ {_[ j_ Charlotte Co. J
ft
12
24 Mites
Figure 1-2. Preferred sites.
1-30
-------
0 1 2 Miles
¦HiMC=ZZZZZZI
Figure 1-3. General location of the Big Bend site.
1-31
-------
I
w
ro
Figure 1-4. Plot plan, Big Bend Station.
-------
Soot
Vent blowing
losses tosses
I
CO
U>
(m) riy)
V Boile
? l_ blowdc
To bay
Evapo1 lion
Bay water
or alternative
water source
<">
Cooling
tower
Blowdown
K"-\ to bav
KKi
(008)
Cfosed-cycfe cooling alternative
Alternative
water source
__ Bottom-ash
iC7>. blowdown
XZy to bav
(010)
<007)
To intake
and discharge
canals
(012 & 013)
:~<§>
Unit 4
condenser
To bay <006)
Once-th rough
cooling alternative
L Percolation
Notes: See Table 1-2 for key.
Numbers in parentheses refer to NPDES Serial Numbers,
Figure 1-5. Plant water balance for Big Bend Station.
-------
V';/'4 '' .VvVV.
cfs cubic feet per second
500
1000 Feet
Figure 1-6, Once-through cooling system for Big Bend Units 1-4.
-------
1.3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
1.3.1 ATMOSPHERE
1.3.1.1 Baseline Conditions at Big Bend
The climate of the site region is subtropical and is frequently affected by
warm maritime air masses throughout the year and occasionally by cold, dry
polar air masses during winter. The modifying effects of the Atlantic Ocean,
the Gulf of Mexico, and Tampa Bay contribute to the relatively mild and humid
winters and the very warm and very humid summers. Occasionally, cold air
masses reach the region during the winter, resulting in freeze conditions.
The region is subject to tropical storm activity.
The site region is within the northeast trade winds zone. Annual prevailing
winds are from the east, with mean speeds generally less than 9 miles per
hour (Figure 1-7). Wind directions are influenced locally by convectional
forces inland and by land and sea breezes near the coast.
The region can be characterized as flat terrain, and significant topographic
effects on dispersion meteorology are not expected. However, atmospheric
dispersion and transport conditions can be significantly affected by coastal
meteorological processes. Data from two sampling sites in the Tampa area
indicate that neutral conditions predominate throughout the year. Unstable
conditions are relatively more frequent during the spring and summer.
The TECO service area lies within the West-Central Florida Intrastate Air
Quality Control Region (AQCR; Citrus, Hardee, Hernando, Hillsborough, Levy,
Manatee, Pasco, Polk, Pinellas, and Sumter Counties). A portion of Hills-
borough County has been designated as nonattaining for suspended particulates
and a portion of Pinellas County has been designated as nonattaining for sul-
fur oxides. The whole of Hillsborough and Pinellas Counties has been desig-
nated as nonattaining for ozone. National and State of Florida ambient air
quality standards (AAQS) applicable to the site are presented in Table 1-6.
The closest prevention of significant air quality deterioration (PSD) Class I
area is the Chassahowitzka National Wildlife Refuge, located approximately
92 kilometers north of the Big Bend site in Hernando County. The remaining
surrounding area is classified as PSD Class II area and thus is subject to
less stringent restraints. The allowable increments by PSD class are presented
in Table 1-7. The ambient onsite concentrations of sulfur dioxide, nitrogen
oxides, and total suspended particulates do not exceed either NAAQS or State
of Florida standards.
1.3.1.2 Impacts of Construction Activities
The most significant atmospheric impacts of Unit 4 construction will be the
dust raised from disturbed land surfaces, the exhaust emissions of construc-
tion equipment and other motor vehicles, and the day-to-day noise endemic to
heavy construction activity.
The dust raised by construction vehicles will be controlled by the spraying
of construction roads with water. The use of dust retardants, windbreaks,
dust fences, or temporary mulching to promote vegetation in dredged soils
1-35
-------
and in other exposed soil areas will be considered where appropriate. The
speed of mobile construction equipment will be controlled so as to minimize
the abrasion and pulverization of the soil.
Concentrations of nitrogen oxides, carbon monoxide, suspended particulates,
sulfur dioxide, and hydrocarbons will increase as a result of engine exhaust
from construction equipment and automobiles used by the construction work
force. These impacts will be minimized through the proper maintenance of
engines and machinery.
It is estimated that construction sound levels will generally be lower than
the existing residual ambient sound level (i.e., the sound level equaled or
exceeded 90 percent of the time). No serious impacts from onsite construc-
tion noise are expected in the surrounding private and public areas.
1.3.1.3 Impacts of Operation
Atmospheric impacts of the operation of Unit 4 will include fugitive dust
emissions owing to the transport, handling, and storage of coal; the emission
of such pollutants as sulfur dioxide, particulate matter, nitrogen oxides, and
carbon monoxide from the coal-fired boiler; and noise.
Potential (uncontrolled) and controlled fugitive emissions from coal handling
are estimated at 900 and 1200 tons per year, respectively. Fugitive dust
emissions from the receiving, handling, and storage of coal will be minimized
by the turning of the reserve coal piles, which ensures uniform surface mois-
ture; the containment and control at transfer points, conveyors, and crushing
equipment; and the proper maintenance of coal-handling facilities.
The air-quality impacts from the operation of Big Bend Unit 4 were determined
by dispersion modeling using EPA-approved models. Table 1-8 compares Unit 4
emissions levels for SO2 with AAQS.
Operation of Big Bend Unit 4 without Unit 3 is considered the worst-case emis-
sions condition for impacts on nonattainment areas, since the stack exit veloc-
ity would be significantly reduced. Table 1-8 lists the SO2 levels that would
be expected in the nonattainment areas. A summary of Class II PSD increment
consumption is included in Table 1-9.
The Class I PSD area nearest Big Bend is the extreme southeastern edge of
the Chassahowitzka Wilderness Area, which is located approximately 92 kilo-
meters from the site. The predicted impacts of sulfur dioxide are below the
significance-of-impact levels, which for sulfur dioxide short-term averaging
times are identical with the Class I PSD increments. Therefore, it is ex-
pected that such impacts at a distance of 92 kilometers will be much less
than the allowable Class I increments.
The emissions of particulate matter from the boiler will be controlled by an
electrostatic precipitator with a design specification of 0.03 pound per mil-
lion Btu and 20 percent capacity. This will result in a particulate matter
emission of 129.9 pounds per hour. Big Bend's compliance with AAQS for total
suspended particulates is reflected in the projections of maximum ambient air
quality impacts presented as Table 1-8.
1-36
-------
The operation of Big Bend Unit 4 without Unit 3 is predicted to result in a
maximum annual average concentration of total suspended particulates of much
less than 1 microgram per cubic meter (Table 1-8).
The maximum PSD increment consumption for total suspended particulates
(24.0 micrograms per cubic meter) occurred 200 meters south of the Agrico
facility. Agrico's impact is expected to be 25.4 micrograms per cubic meter;
therefore, there is a slight improvement in air quality. Only slight dete-
rioration (0.3 microgram per cubic meter) is expected beyond 0.3 kilometer.
The emission of nitrogen oxides from the boiler will be controlled using a
tangentially fired boiler having a design specification of 0.60 pound per
million Btu and nitrogen oxide emissions of 2598 pounds per hour. The maxi-
mum annual nitrogen dioxide concentration from the operation of Big Bend
Unit 4 is 0.5 microgram per cubic meter and is below the level of significant
impact.
The maximum 3-hour carbon monoxide impact (developed using maximum 3-hour sul-
fur dioxide impacts) is 7.8 micrograms per cubic meter. This concentration
is far below the level of significant impact and the resultant impacts will
not violate AAQS.
All the sound levels due to the operation of Big Bend Units 1-4 are expected
to meet or be below the maximum daytime (60 dBA) and nighttime (55 dBA) res-
idential sound levels permissible under the Hillsborough County noise code.
The nighttime intermittent sound levels are expected to range from 3 to
10 dBA higher than the residual nighttime levels, and the daytime intermit-
tent sound levels are expected to be as much as 17 dBA higher than the re-
sidual daytime levels. However, similar variations in ambient sound levels
presently occur because of variations in existing ambient noise sources.
Therefore, noise from the operation of Unit 4 is expected to have no signif-
icant impact on the surrounding private and public areas.
1.3.1.4 Impacts of Cooling Towers
Potential impacts on the atmosphere from the operation of a mechanical-draft
cooling tower include the effects of salt drift, ground-level fogging, and
increased noise levels.
The potential occurrence of ground fog would be infrequent and generally
confined to the immediate site area.
Salt drift from cooling towers is potentially subject to air quality regula-
tions, including emission limitations, air quality standards, and PSD and
emission offset regulations. The total drift emission, using a drift rate
of 0.002 percent and a circulating water salinity of 42 parts per thousand,
would be about 105 pounds per hour or 5 pounds per hour over allowable
emissions.
Before definitive conclusions can be reached for Big Bend Unit 4, the com-
bined effects of the stack, cooling towers, and other sources would have
to be modeled together. The modeling would necessarily be based on a
1-37
-------
definition of suspended particles that would be acceptable to the appropri-
ate regulatory agencies. The results of the modeling would then have to
be compared to the "available" increment, which may be less than the total
increment.
The impacts of cooling towers with brackish or freshwater makeup would pre-
sumably be similar to those described for the saltwater cooling tower. How-
ever, drift effects would be less severe. The reduced content of dissolved
solids in the water would allow for a higher concentration factor (ratio of
solids in the circulating water to solids in the makeup water) and higher
drift rates. Alternatively, with equivalent drift rates, the salt deposi-
tion would be less than with saltwater makeup. The precise impacts would
depend on the concentration of dissolved solids in the drift.
Noise impacts from mechanical draft cooling towers would meet applicable
county noise codes.
1.3.2 LAND
1.3.2.1 Baseline Conditions at Big Bend
The Big Bend site is located on artificial fill dredged from the bottom soils
of Tampa Bay. Unconsolidated materials lie beneath the artificial fill and
overlie layered sedimentary rocks in two formations, the Hawthorn Formation
and the Tampa Formation. These formations are composed principally of car-
bonate rocks, although the Hawthorn Formation contains a number of uncemented
sediments.
Three soil associations occur at the Big Bend site. The Ruskin-Sunniland-
Bradenton association covers approximately 70 percent of the Big Bend site
area, and the saltwater swamp and marsh association covers about 25 percent.
The remaining area is covered by the Ona-Scranton-Leon association.
Surveys of terrestrial flora and fauna, conducted at the Big Bend site during
the period 1972 to 1977, were used as baseline data for the assessment of the
environmental impact of the proposed Big Bend Unit 4.
The Big Bend site encompasses approximately 1,675 acres on the eastern shore
of Hillsborough Bay. The distribution and areal extent of land use and veg-
etation cover types on the site, as determined from 1977 aerial photography
are presented in Figure 1-8. The photographic data showed that approximately
30 percent of the site (mostly dredge-and-fill land) was committed to construc-
tion, electric-power-generating units, and associated facilities; 18 percent
supported natural vegetation cover; 24 percent was improved or unimproved pas-
tureland for cattle; 19 percent was intermixed with ponds and marsh; 1 percent
was devoted to private residences; and 8 percent had other combined uses.
The natural vegetation at Big Bend has been greatly disturbed by human ac-
tivities such as logging, cultivation, cattle grazing, construction, and the
maintenance of transmission corridors. Consequently, the majority of vascular
plants are ruderal.
Vegetation types observed on the Big Bend site during 1974-1975 were charac-
terized as follows. Agricultural land was approximately 24 percent of the
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site and included both cultivated fields and pastureland for cattle# Re-
cently abandoned agricultural land occupied approximately 12 percent of the
site and was represented by a variety of old-field associations. Pine flat-
woods accounted for approximately 4 percent of the site and was one of the
less disturbed communities on the site. A mangrove community occupied about
12 percent of the Big Bend site and formed a distinct vegetational zone
along the southwestern coastal portion of the site where tidal flushing
occurred. This was the oldest and least disturbed community on the site.
Salt prairie occupied approximately 3 percent of the site and was dominated
by halophytic plant species. There were also two small areas of impeded
soil drainage on the site which were classified as freshwater wetlands.
Included in one area was a small pasture pond surrounded by a low marshy
area. During the 1977 survey, most of the open water had disappeared due
to encroachment of herbaceous species.
In addition to the areas already discussed, a freshwater drainage canal
traversed the southern portion of the site. The eastern end of the drain-
age canal was headed by a small freshwater marsh. The western portion of
the canal merged with a brackish mangrove-Spartina marsh before discharging
into Tampa Bay. The species in this area included both mesic and halophytic
plant forms.
Terrestrial fauna that have been reported from the Big Bend site include
104 species of birds, 21 of which are species of special status; 19 species
of mammals; and 6 species of amphibians. Also, 56 species of reptiles have
been reported in Hillsborough County and could occur in terrestrial and
aquatic habitats at the site.
1.3.2.2 Impacts of Construction Activities
The primary impacts associated with the construction of Unit 4 will include
the commitment of approximately 41 acres of land for parking, equipment
laydown, construction workshops, temporary storage of excavated material,
and the erection of buildings that comprise and are associated with Unit 4.
Unit 4 plant structures will require approximately 7 acres of land. An addi-
tional 7 acres will be designated for the coal reserve and service facilities
associated with Unit 4. A railroad spur will also be constructed at the
site. Much of the area that will be temporarily committed to laydown, park-
ing, and excavated-material storage during construction will be restored
during or after the completion of construction.
Clearing and construction activities will result in the displacement or elimi-
nation of all sedentary fauna (primarily small mammals) that may presently
inhabit this area. This is not considered an important long-term ecological
impact since these species most likely exist in more stable populations in
nearby, less disturbed areas.
In addition to the 41 acres previously described, approximately 97 acres
will be preempted by the sites for the storage and disposal of flue-gas
desulfurization (FGD) byproduct gypsum. These 97 acres consist of approxi-
mately 66 acres of pastureland (including a small pond less than an acre
in size and an associated marsh) and 31 acres of agricultural land.
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The pastureland consists primarily of ruderal or weedy species of herbaceous
vegetation. At the time of the ecological surveys conducted in 1977, this
land was no longer being used as a cattle-grazing area. The 1974-1975 sur-
veys showed that the pasture and pond/marsh areas supported a relatively
small number of vertebrate species by comparison with less disturbed habitats
at the Big Bend site. The 1977 survey indicated that most of the pasture
pond had disappeared and vegetation was more typically old field (i.e., drier)
than marshland. There was also an increase in vertebrate species preferring
old-field habitats and a sharp decrease in the number of marshland species;
marsh birds were notably absent from the area. The 31 acres of agricultural
land represent supplemental sources of food and cover for wildlife, but their
availabiliy depends on the types of crops planted and the frequency of
tillage.
The development of the proposed gypsum storage and disposal area represents
a long-term commitment of these pasture and agricultural lands. However,
the preemption of these plant communities and wildlife habitats is more
ecologically acceptable than that of other available parcels at the Big
Bend site for two reasons: (1) these habitats have been recently disturbed
and are not unique to the Big Bend site or the surrounding areas; and
(2) they are among the least biologically important wildlife habitats at the
site.
The ash-disposal ponds for Unit 4 will require 121 acres of land. The
bottom-ash pond will be located in the area currently occupied by an unused
U-shaped cooling pond. The fly-ash pond will be located adjacent to the
bottom-ash pond on land classified as "old field." The impacts of the
preemption of this area will be similar to those described in the previous
paragraphs.
The only construction associated with the transmission lines for Unit 4 will
be the installation of an additional 230-kilovolt circuit on the existing
towers. There will be no need for a new right-of—way. Land areas beneath
the transmission line (1) are zoned for industrial purposes, (2) do not in-
clude critical wildlife habitats, and (3) do not require the presence of
man-made structures or alterations of terrain. Vegetation may be disturbed
temporarily by vehicles carrying equipment, but since this will not affect
any mature forest or important flora, irreversible impacts are not expected.
Erosion problems also are not expected; however, should any problems develop,
mitigation will be effected by the use of mulch, temporary or permanent
vegetation, or erosion-control fabrics.
Dredging associated with the construction and installation of the Unit 4
cooling-water intake and discharge structures involves only a small amount
of spoil material. This will be removed by clamshell and trucked to the
two existing dredge-disposal areas. No discharge from the disposal areas
is expected.
The conceptual location for a mechanical-draft cooling tower is directly
south of the Unit 4 plant structure on the south bank of the discharge
canal. The tower would be located so as to minimize impact on the nearby
mangrove area.
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The noise produced by construction equipment and related activities could
have an impact on wildlife in the vicinity of the Big Bend powerplant.
Responses of vertebrate fauna to construction noise may vary from species
to species and will depend on distance from the powerplant and from other
intrusive-noise sources. Species nearest the plant may undergo periodic
"startle reactions" and move away from the noise source (if possible) when
peak-construction sound levels occur; however, most of the species nearest
the plant are expected to have adjusted to the existing noise from the
operation of Units 1, 2, and 3. Fauna inhabiting areas other than the
gypsum storage and disposal area should experience little, if any, increase
in noise levels during construction. For this reason, no measurable effects
of construction noise on species occurring near or beyond these locations
are expected.
Site restoration will begin during the latter stages of construction or
after its completion. Certain areas will be surfaced with crushed stone
to maintain areas frequently used by maintenance personnel and heavy equip-
ment. Trees, shrubs, and ground cover will also be planted during site res-
toration. The vegetation will be selected to satisfy three primary objec-
tives: (1) the stabilization of soils, (2) the creation of an aesthetically
appealing physical plant and surrounding area, and (3) the establishment of
wildlife habitats and food sources.
1.3.2.3 Impacts of Operation
Terrestrial impacts from operation of Big Bend Unit 4 may result from coal
handling and operation of the sulfur dioxide and particulate emissions con-
trol systems.
Because the coal will be received, stored, and handled in the same manner
and with the same facilities as are now used for Units 1, 2, and 3, no ad-
verse impacts on the terrestrial ecosystem are expected. Impacts due to
dust and noise may occur, but these will be minor and will not affect the
important wildlife or their habitats. Runoff from the coal-storage pile
will be controlled by retention trenches, and contamination of adjacent
soils is not expected.
The primary impact on terrestrial systems from the operation of the sulfur-
dioxide-control system will be the preemption of approximately 97 acres of
land for the gypsum storage and disposal area. Depending on the marketabil-
ity of the gypsum, onsite storage and disposal will either temporarily or
permanently remove the area from further use for the lifetime of the plant.
The gypsum will be transported to the propsed site by means of a conveyor
system and will be handled by bulldozer. At this stage, it should contain
approximately 10 percent water; therefore, it should not undergo wind erosion
or create a fugitive-dust problem during transport.
If permanent disposal is necessary, the material will be landfilled in a
heaped fill configuration. Experience with this type of landfill has shown
that problems arising in the areas of ground-water pollution, slope stability,
and site preparation are minimal in comparison with other disposal methods.
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Fugitive-dust problems are not expected, since the gypsum, when left undis-
turbed, forms a protective crust that minimizes wind erosion and dusting
tendencies.
The primary impact on terrestrial systems from the operation of the particu-
late control system will be the preemption of 121 acres for the settling
ponds and disposal cells for bottom ash, unmarketable fly ash, pyrites re-
moved from the coal before combustion, and economizer ash. Other potential
terrestrial impacts from the control of particulates include (1) the use of
active disposal ponds by waterfowl and (2) the effects of runoff and seepage
from disposal sites.
The presence of a large body of standing water can sometimes be attractive
to waterfowl as a resting and feeding area, particularly if there are sources
of food nearby. Ash-settling ponds are examples of such bodies of water.
Waterfowl using these ponds are thus exposed to potentially harmful partic-
ulates and chemicals dissolved in the water.
During the operation of a powerplant, runoff from the onsite waste impound-
ment is unlikely if the dikes confining the ash are properly constructed.
Vertical and lateral seepage from unlined ash-disposal sites can occur,
particularly where the waste material is deposited as a slurry. The major
impact of seepage is the addition of potentially toxic elements and ions
to soils, ground water, and surface waters. In addition, seepage introduces
radionuclides and other potentially harmful elements into the growth medium
of local vegetation.
The bottom-ash settling ponds for Big Bend Unit 4 will be unlined and de-
signed to store approximately 6 months of ash production. As these ponds
are filled, the ash will be hydraulically dredged to final disposal cells.
The settling ponds and disposal cells for unmarketable fly ash, pyrites,
and economizer ash will be lined and enclosed by earthen dikes. Liner mate-
rial will have a low permeability (0.0000001 centimeter per second).
1.3.2.4 Impacts of Cooling Towers
The primary impact on terrestrial systems from the operation of mechanical-
draft cooling towers using saltwater makeup will be salt deposition due to
drift. The drift predictions for the mechanical-draft tower are given in
Figure 1-9, which shows annual average deposition rates within approximately
1 mile of the proposed tower location.
The data suggest that there are two areas near Big Bend Station of primary
importance in evaluating the potential terrestrial impacts of cooling-tower
salt emissions. One area consists of the palmetto-Juncus and palmetto-pine
associations in the area adjacent to and south of the proposed cooling-tower
location. Based on the predicted salt levels and on the reported suscepti-
bility of vegetation to salt damage, it would appear likely that much of the
vegetation in the palmetto-pine and palmetto-Juncus associations would be
severely injured as a result of foliar salinization.
The other area of primary importance lies to the east and southeast of the
cooling tower. Within this area, crops such as tomatoes, red peppers, sweet
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onions, and strawberries are grown commercially. Of these crops, tomatoes
are moderately salt-sensitive and peppers, onions, and strawberries are very
salt-sensitive. The occurrence and salt tolerance of ornamentals in offsite
residential areas are presently unknown.
The synergistic effects of cooling-tower drift and stack emissions (e.g.,
sulfur dioxide, nitrogen oxides, and particulates) represent another poten-
tial source of damage to vegetation near Big Bend Station.
The impacts of cooling towers with brackish and freshwater makeup would
presumably be similar to those described for the saltwater cooling tower.
However, drift effects would be less severe because of differences in the
makeup water. The reduced content of dissolved solids in the water would
allow for a higher concentration factor (ratio of solids in the circulating
water to solids in the makeup water) and higher drift rates. Alternatively,
with equivalent drift rates, the salt deposition would be less than with
saltwater makeup. The precise impacts would depend on the concentration
of dissolved solids in the drift.
1.3.3 WATER
1.3.3.1 Baseline Conditions at Big Bend
Surface and Ground Water Hydrology
Big Bend Station is located near the mouth of Hillsborough Bay, a north-
easterly extension of the Tampa Bay estuarine system which has a total
surface area of approximately 350 square miles and a shoreline of approxi-
mately 210 miles. The mean water depth is 11 feet, and 90 percent of the
estuary is less than 22 feet deep. The drainage area of the T
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Newman Branches. These ditches carry water only during and immediately
after heavy rainfall.
In Hillsborough County, ground water occurs in a series of unconfined, semi-
confined, and confined aquifers composed of undifferentiated surface sands
and clays. The water table generally yields about 5 gallons per minute in
wells 20 feet deep. A major source of this water is local rainfall, with
an estimated 700 cubic feet per second of precipitation infiltrating into
the aquifer.
Underlying the water-table aquifer is the shallow artesian aquifer in the
sand and limestone beds of the Hawthorn Formation. These beds are approxi-
mately 65 feet thick at the Big Bend site. Wells in this aquifer yield up
to 500 gallons per minute of water of relatively poor quality. The aquifer
is recharged by upward leakage from the Floridan aquifer.
The ground—water body under the site has average water—table elevations
ranging from 5.5 to 4.0 feet above mean sea level during nondrought periods.
Available literature suggests that the water table drops considerably dur-
ing periods of severe drought. There is also evidence of contamination of
the water table by inflows of saltwater. The permeability of the first
15 feet of soils ranges from 0.01 to 0.0001 centimeter per second. During
a 1973 geotechnical investigation, the water table along the northern edge
of the proposed gypsum storage/disposal area was monitored by means of four
shallow wells. The data collected revealed a hydraulic gradient on the
order of 0.006 foot per foot, which indicates ground-water flow from east
to west. The transmissivity of the surficial aquifer was estimated to be
1060 gallons per day per foot with a flow rate on the order of 0.6 gallons
per day per foot of aquifer width.
Surface and Ground Water Quality
Hillsborough Bay is bounded on the west, north, and northeast by the City
of Tampa. Numerous heavy-industrial facilities and port terminals are
located along the north and northeast shores of the bay. Hillsborough Bay
waters are generally regarded as the most polluted of the Tampa Bay system.
The pollution is attributable to the discharge from sewage-treatment plants,
numerous industrial pollutants, and large amounts of nutrients (introduced
naturally from rivers and artificially from various phosphate-industry-
related activities). In addition, the region is one of low salinities and
high turbidities.
Water temperatures in the Tampa Bay system range from 10.0 to 32.0°C , with
a mean annual temperature of 22.0 to 25.0°C, and a naturally occurring maxi-
mum of 36.9°C. Hillsborough Bay has a range of 11.2 to 35.1°C. Water tem-
perature near the Big Bend site has increased since the 1970 startup of Big
Bend Unit 1. Following startup of Big Bend Unit 2 in early 1973, data
collected during monitoring programs indicated the annual means and ranges
of water temperature near the site had increased several degrees over the
published averages for Tampa Bay.
Water quality data for Hillsborough Bay are presented in Table 1-10, and
Table 1-11 contains information on the quality of water collected in the
Big Bend intake canal.
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The water quality of the surficial aquifer at the Big Bend site is given
in Table 1-12. The surficial aquifer has relatively high concentrations
of chloride, sodium, sulfate, and calcium, indicating that saline water
has mixed with water traveling downgradient in the surficial aquifer. The
water exceeds EPA standards for chloride, sulfate, manganese, and total
dissolved solids, and exceeds the suggested standards for arsenic.
Data on the water quality of the Floridan aquifer in the site area are
limited. Characteristics of the aquifer in the general Tampa Bay drainage
area are presented in Table 1-13. Table 1-12 lists water-quality data
for several parameters based on the concentrations measured from several
wells in the site area. The sulfate concentration exceeds EPA-recommended
drinking-water limits.
Aquatic Ecology
Numerous investigations of the ecology of the Tampa Bay system in the vicin-
ity of Big Bend have been conducted by the Applicant and others on an inter-
mittent basis since 1960.
Phytoplankton. A total of 133 phytoplankton taxa were recorded from the
vicinity of the Big Bend powerplant during a study conducted in 1976-1977.
These taxa included 83 diatoms, 42 dinoflagellates, and 8 other groups.
Ten taxa comprised more than 90 percent of total phytoplankton organisms
collected with diatoms accounting for the largest portion of these phyto-
plankton. It should be noted that only the larger, armored phytoplankton
forms were collected in the coarse-mesh nets used in these studies. Un-
accounted for were the small, fragile species (i.e., "naked" flagellates),
which typically make up the larger percentage of phytoplankton organisms
occurring in estuarine systems.
Planktonic blue-green algae (primarily Oscillatoria sp.) shared dominance
with diatoms or dominated phytoplankton numbers from late summer through
early fall.
Macrophytes. Several largely qualitative studies of the benthic macrophyte
communities in Tampa Bay have included sampling sites in the Hillsborough
Bay and Big Bend areas.
During a field survey of benthic macrophyte distribution conducted in Tampa
Bay during the fall of 1960, attached benthic plants were found only in
sparse, scattered patches in the Hillsborough Bay. In the shallow waters
of the Big Bend area, however, shoal grass (Halodule) was common and widgeon
grass (Ruppia) abundant; offshore, within the 1-fathom contour, manatee
grass (Syringodium) was abundant and Ruppia sparse.
Data collected during the period 1970-1973 suggested that benthic macrophytes
in the Big Bend area were sparsely distributed and of limited diversity.
However, the limited qualitative studies conducted from 1970-1975 do not
allow for a definitive evaluation of the possible effects of powerplants
or other activities on macrophyte distribution.
During quantitative surveys conducted quarterly at Big Bend during 1977-
1978, seagrass-sampling transects were established in the dilution-pump
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intake canal, in the embayraent south of the discharge canal, and in a con-
trol area located south of the main study area.
In contrast to the control area, only one seagrass species, R^. maritima,
was observed at the embayment stations. The degree of coverage and density
varied widely during sampling. Ruppia were completely absent at sampling
stations during September and December of both study years. Coverage and
density were very low during both years on the transect located at the
former site of thermal discharge into the embayment. On the test transect
near the dilution-pump intake, only limited coverage of H_^ wrightii was
observed and this only sporadically.
The differences between the transects in the control area and in the test
areas near the plant may have resulted from past dredge-and-fill activities
related to powerplant construction and to other development in the area
(e.g., Apollo Beach residential communities), as well as possible thermal
effects of powerplant operation.
Zooplankton. Studies carried out over the period 1970-1975 revealed t^ia^
the zooplankton community in the area of Big Bend was typically dominate
by copepods, of which cyclopoids were generally more abundant than calanoi s.
Copepod nauplii, pelecypod (bivalve) and gastropod veliger larvae, and poly
chaete larvae were also abundant. Organisms that were seasonally abundant
included echinoderm and cirriped larvae, cladocerans, appendicularians,
rotifers, and tintinnids.
Zooplankton studies were also conducted from January 1976 to March 1977 as
part of an investigation for Units 1, 2, and 3 to evaluate the distribution,
abundance, and entrainment potential for the planktonic stages of fish an
benthic invertebrates (meroplankton).
Eggs from 12 families of fish were collected during the 15-month study. Two
families, Engraulidae and Sciaenidae, accounted for 73 and 26 percent, re
spectively, of all eggs collected. The collections included larvae of 41 spe-
cies of fish in 22 families. Again, engraulids were the most common larvae,
accounting for 87 percent. Both fish eggs and larvae were taken during
every month of the study. The greatest densities occurred during spring
and summer; the lowest, during winter.
The bay anchovy, an important forage species, was the most common engrau
lid. Members of the economically important family Sciaenidae accounte
for 26 and 4 percent, respectively, of all fish eggs and larvae collected.
The specific identification of sciaenid eggs and early larvae is genera y
not possible. However, based on those larval stages that could be i en
tified, sciaenids accounted for a larger number of species than any other
fish family. The species collected included silver perch, sand seatrout,
spotted seatrout, spot, southern kingfish, northern kingfish, and black
drum.
Larval clupeids, carangids, pomadasyids, sparids, and gobiids were also
commonly taken in spring and summer, although each family accounted for
less than 3 percent of all larvae collected. Winter samples were domi-
nated by blenny and goby larvae, but numbers were usually low. The larvae
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of pinfish, menhaden, and spot migrated into the study area daring January
and February.
A total of 105 invertebrate taxa, of which 86 were decapod crustaceans
(shrimp, crabs, etc.), were recorded from the meroplankton collections,
made from 1976 to 1977. Larval decapods accounted for 94 percent of the
larval invertebrates taken in the collections. However, nondecapod inver-
tebrate larvae, which are typically the numerically dominant meroplankton
organisms in the area, were undoubtedly underestimated because they passed
through the mesh (363 micrometers) of the sampling nets.
Commercially important taxa included the larvae of stone crab and blue crab,
and the postlarvae of pink shrimp.
Studies conducted at 3ig Bend from February 1979 to February 1980 concen-
trated on the distribution, abundance, and entrainment potential of mero-
planktonic stages of a select group of "representative important species"
(RIS) of fish and invertebrates. Additional analyses were conducted on
selected samples to compare the distribution, abundance, and entrainment
potential of RIS taxa with that of other meroplankton taxa.
The bay anchovy was the most abundant RIS taxon. Representative important
species of the family Sciaenidae collected during 1979-1980 included silver
perch, spotted seatrout, and black drum. A large number of unidentifiable
eggs with characteristics common to the family were grouped as "Unidentified
Sciaenid Eggs." (At least nine species of this family are known to occur
in the Big Bend area.)
The selected samples collected from March to October contained the eggs and
larvae of 16 additional species representing 13 fish families. The eggs and
larvae of the bay anchovy, an RIS fish, were more abundant than those of any
other fish species in the selected samples, accounting for 50 and 74 percent,
respectively, of all fish eggs and larvae. Unidentified Sciaenidae accounted
for most (48 percent) of the other fish eggs. Other families represented by
eggs included Soleidae, Carangidae, Clupeidae, and Triglidae. The scaled
sardine ranked second in larval abundance (16 percent). Other species aver-
aging more than 1 percent of total fish larvae were the feather blenny and
the sand seatrout, which accounted for 1.5 and 1.1 percent, respectively.
Other commercially important non-RIS fish that were taken as larvae include
kingfish, sheepshead, and pigfish.
Of the invertebrate RIS taxa, only stone crab larvae and pink shrimp post-
larvae occurred in the 1979-1980 collections. The presence of larvae of the
eastern oyster was demonstrated by oyster spat studies.
In addition, larvae of the brief squid (Lolliguncula brevis), which has
commercial value in the Tampa Bay area as bait, occurred in the collections
during April and May.
Benthic Invertebrates. Studies of Tampa Bay have indicated that the bay
system, in general, supports an abundant and diverse assemblage of benthic
invertebrates. However, in Hillsborough Bay and several other areas of the
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bay system, dredge-and-fill operations and pollution, both domestic and in-
dustrial, have resulted in the presence of soft, highly organic sediments,
a high biological oxygen demand, and low dissolved-oxygen concentrations,
conditions that severely limit the distribution, diversity, and abundance of
benthic invertebrates.
Early benthic studies at Big Bend were largely qualitative. Studies from 1970
to 1975 in the nearshore area near the plant revealed organism assemblages
typical of a highly disturbed estuarine environment. The findings were at-
tributed to the highly disturbed nature of the sediments in the area, likely
a result of the extensive dredge-and-fill operations and other construction
activities at the powerplant site, Apollo Beach, and nearby waterfront resi-
dential areas.
A total of 337 benthic infaunal invertebrate taxa were recorded at Big Bend
during 1976-1977. Nine species accounted for approximately 70 percent of
the total number of organisms.
Studies of the benthic infauna were conducted during 1979 to evaluate the
ecological effects of a shutdown of the Big Bend power-plant dilution pump-
ing system.
Comparison of the results of the studies reveals a dramatic change in the
area. The early studies revealed an abundance of malltisks and crustaceans.
¦©utxts® 1919, the Wathxc itiiaurta were composed mainly of polychaetes and
other deposit feeders. During 1979, the general distribution of the dominant
taxa near the plant discharge and in the embayment south of the discharge
canal differed from that at all other stations studied. The results suggest
the presence of "pioneer" conditions at these stations (i.e., an abundance
of pollution-indicator and opportunistic species). In general, both density
and species richness at all open-bay stations were considerably lower during
1979 than during 1976. Species diversity and equitability in 1979 were com-
parable to or greater than those in 1976, probably because of the reduced
dominance of a single species. Differences in species composition and com-
munity parameters between the two study years were not restricted to the
thermal areas; rather, they appeared to reflect an area-wide change in the
benthic community. The dramatic change in benthic species composition,
apparent from the 1979 studies, was viewed as the result of a combination
of natural cyclic phenomena and perturbation of the entire Tampa Bay system
owing to the extensive dredging activities of the Tampa Harbor Deepening
Project.
Fishes. Juvenile and adult fish were collected by seine and trawl in the
Big Bend area from 1970 to early 1977 and during 1979-1980. The objectives
of the earlier studies were to determine the composition and the temporal
and spatial distribution of the fish community in the vicinity of Big Bend
and to evaluate powerplant effects on the community. The 1979-1980 study
was designed to provide information on RIS fish taxa for assessing the
potential effects of Big Bend Unit 4.
During 1976-1977, a total of 61,273 fish representing 56 species in 32 fami-
lies were collected in 180 seine hauls. Most fish were collected in the
shallow inshore areas. The tidewater silverside was the most common fish,
followed in relative abundance by the bay anchovy and the longnose killifish.
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Most of the fish commonly collected in 1976-1977 also had been dominant
during previous quantitative sampling in the study area.
The findings suggested that the habitats represented by these areas served
as nursery areas, the northern embayment formed by Apollo Beach apparently
being the most important. Overall, the seine studies revealed the transient
nature of the fish community in the Big Bend area. Most catches were gen-
erally dominated by a few species (two to six), but the dominants changed
with time. Seasonal influxes of certain species caused shifts in community
structure throughout the study period. This phenomenon was particularly
pronounced at the "nursery" stations.
Fewer bay anchovies were collected by seine during the 1979-1980 study than
in 1976-1977. Most fish collected in 1979-1980 were adults in spawning con-
dition. However, in the earlier investigation, which included stations not
sampled in 1979-1980, several thousand juveniles were taken.
The tidewater silverside was the most abundant and ubiquitous fish collected
in seine hauls during 1979-1980. The silver perch, typically a deep-water
species, was not collected by seine but was the most abundant RIS fish taken
by trawl, primarily in the plant discharge canal.
A total of 47 non-RIS fish species were collected by seine. The five most
abundant species were longnose killifish, spot, pinfish, sheepshead minnow,
and rough silverside. The trawl catch included 43 non-RIS species. The
five species most commonly collected were sand seatrout, pinfish, sea cat-
fish, spot, and pigfish.
In general, the seasonal trends observed in non-RIS species composition and
relative abundance during 1979-1980 are consistent with those observed in
previous studies in the Big Bend area. Any differences could be attributed
to the natural cyclic variations in distribution and abundance typical for
many estuarine organisms.
Manatee. The Florida or West Indian manatee is listed as an endangered
species by the Federal Government and by the Florida Game and Fresh Water
Fish Commission. It is also considered threatened by the Florida Committee
on Rare and Endangered Plants and Animals. In U.S. waters, manatees are
protected by the Marine Mammal Protection Act of 1972.
Manatees have been frequently sighted along the eastern shore of Tampa Bay,
including Hillsborough Bay, and in the Little Manatee, Alafia, and Hills-
borough Rivers. Winter congregations have been reported at Big Bend. The
U.S Department of the Interior has listed the Little Manatee River below
Route 301 and the Alafia River from the U.S Highway 41 bridge west for
1 mile to its confluence with Tampa Bay as critical habitat for manatees
in Hillsborough County.
TECO sponsored a study of the occurrence of the manatee in Tampa Bay and in
the vicinity of the Big Bend site between November 1979 and February 1980.
The purpose was to document the use of the Big Bend warm-water discharge
canal by manatees and to compare the significance of the site as a winter
refuge against other refuges available in the area. Manatee sightings were
most common at the mouth of the Manatee River during the warmer months and
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in the warm-water refuges during colder months. The highest count during
a single aerial survey was 55.
As a warm-water refuge, the Big Bend powerplant ranked second in importance
to the Gardinier Phosphate Plant on the Alafia River. As many as 10 manatees
were observed at Big Bend during a single survey, while up to 42 were sighted
at the phosphate plant during an overflight in February. The eastern end
of the Big Bend discharge canal (except for the boat ramp area) appeared
to be the region most regularly used by the manatees.
Use of the area by manatees may increase with the increase in thermal dis-
charges attributable to the operation of Big Bend Unit 4. Manatees could
occur in the area during critical temperature drops in early winter, espe-
cially when the air temperature drops below 10°C and water temperatures in
the thermal plume range from 16 to 20°C. They are not expected to remain
in the area the entire winter, but should migrate to other nearby areas in
Tampa Bay when the air and water temperatures increase. Their occurrence
will also depend on food availability in the discharge area.
Dolphins. Twenty-one species of cetaceans (dolphins and whales) have geo-
graphic ranges that could include Tampa Bay or adjacent waters of the Gulf
of Mexico, but only the bottle-nosed dolphin is expected to occur in the
Big Bend area with any regularity. This species, like all cetaceans, is
protected by the Marine Mammal Protection Act of 1972. During the Applicant-
sponsored aerial survey of Tampa Bay from June 1979 to February 1980, a
total of 66 dolphin herds and another 140 individuals were sighted.
1.3.3.2 Impacts of Construction
Construction of the Unit 4 discharge structure will have a primary impact
on the aquatic environment. This structure will be located in the 350-foot-
wide plant discharge canal east of the existing Unit 3 outfall* Approxi-
mately 690 cubic yards of sand and silt will be dredged from an area extending
80 feet in the canal. It is estimated that 3,205,000 benthic invertebrates
will be removed in the dredge material. The benthic corauunity in the discharge
canal is dominated by species that are classified as opportunistic or as
characteristic of thermally stressed areas. A silt barrier will be main-
tained during the operation.
It is expected that those fish inhabiting the discharge canal would avoid
areas of activity and would return after construction is completed. Manatees
congregate occasionally in the warm waters of the discharge canal during the
winter months. Discharge construction activities will be scheduled so as
to cause minimal interference with the activities of this endangered species.
The intake structure for Unit 3 will be extended to provide for the Unit 4
circulating-water pumps and the fine-mesh-screen enclosure. Approximately
420 cubic yards of sand and silt will be dredged from a 50- by 55-foot area
to accommodate the structure. Loss of some benthic invertebrates is expected.
Silt barriers will be used during this construction.
During construction, the ground-water elevations in the immediate vicinity
of Unit 4 will be lowered by the gravity dewatering system required for
earthwork. The results of previous field-dewatering tests suggest that
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this dewatering activity will not have any noticeable effects on private
or agricultural wells in the area, either in the available quantity of water
or in its quality. Since the construction site is on a narrow peninsula,
the ground-water quality in the area is highly influenced by, and similar
to, the bay-water quality. The construction dewatering effluent will be
discharged to the intake and discharge canals (NPDES Serial Noa. 012 and
013). After construction, the dewatering system will no longer be needed,
and ground water will be allowed to rise to its natural elevation.
For construction of the bottom- and fly-ash disposal pond areas, it will be
necessary to relocate Jackson Branch to a course east and north of the dis-
posal areas. Approximately 2400 feet of channel will be bypassed and filled
(a volume of some 15,250 cubic yards) and 2900 feet of new channel will be
constructed. Cut material from the new channel will be used to fill the
old channel or hauled to upland disposal sites. The relocated portion of
the stream bed will initially have a substrate of disturbed naturally occur-
ring material, predominantly shelly sand. The stream bank will be allowed
to revegetate naturally and is expected to resemble portions of the present
stream bed after a few years. The productivity of the relocated portion
of the stream will be appreciably decreased; however, since the stream-
area inflow is small, it is expected that this loss of productivity will
have no observable effect on Tampa Bay. The ash-disposal ponds will be
diked for the 100-year flood, so there will be no stormwater discharge
into the relocated Jackson Branch channel.
The construction of the gypsum storage and disposal areas will not disturb
the main channel of Newman Branch. Small drainage swales and ditches, pre-
viously constructed to drain the area for agricultural use, will be filled
before and during the use of this area for gypsum storage and disposal.
These swales and ditches are nontidal and intermittent water courses. It
is therefore expected that there will be little or no impact on the biota of
Newman Branch or Tampa Bay as a result of their removal. Since the gypsum
storage and disposal area will be diked for the 100-year flood, there will
be no stormwater runoff from this area.
Dredge spoil and cut material from Unit 4 construction will be disposed
of at either or both of the two dredge disposal areas that were used for
construction related to Units 1-3. No discharge from the disposal areas
is expected.
Maintenance dredging has been performed at Big Bend in the past, and it is
conceivable that some maintenance dredging for Unit 4 will be necessary in
the future. Depending on the location and volumes, either clamshell or
hydraulic dredging will be used. At present, when material is hydraulically
dredged to the disposal areas, overflow is discharged to the bay via the
local canals. The overflow from the process, other than being slightly
more turbid, is similar to bay water. Adjustable flashboard risers and
silt barriers are used for controlling the water quality.
There will be no discharge of runoff degraded by construction of the unit
building, the FGD system, and the limestone facilities. All such runoff
will be intercepted and pumped to the wastewater-treatment pond.
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1.3.3.3 Impacts of Operation
The potential impacts of the operation of Unit 4 on water quality, aquatic
ecology and water resources include those due to coal handling, the sulfur-
dioxide-control system, the particulate-control system, and the once-through-
cooling alternatives. Impacts from freshwater usage and the wastewater—
treatment system also may occur.
Impacts of Coal Handling
A coal-pile runoff collection and treatment system has been provided for Big
Bend Station Units 1, 2, and 3. It is designed to capture and retain runoff
resulting from a design storm established by the U.S. Environmental Protection
Agency (the most severe 24-hour storm that can be expected once in 10 years).
To accommodate Unit 4, the runoff collection system will be modified to
intercept all storm runoff and pump it to the existing demineralizer-waste
sump for transfer to the wastewater pond.
Most of the leachate from the coal pile will be collected in ditches for
transport to the wastewater pond. The amount of leachate that does infil-
trate into the ground water is expected to be less than or equal to the
natural recharge and should be insignificant. Since the peninsula on which
the plant is sited is dredged material, the ground water beneath the coal
pile is bay water. The impact of the leachate on this water will have to
be judged in terms of the quality of the intruded bay water and on the
amount of leachate generated by the proposed expansion of the existing
coal pile.
Impacts of Sulfur Dioxide Control
The limestone pile for the flue-gas-desulfurization (FGD) system will be
located on the peninsula and will cover an area of about 1.5 acres. The
pile will be enclosed by a covered building to control limestone moisture.
This will prevent runoff and leachate production.
Runoff from the FGD storage and disposal site can directly affect surface-
water quality, and leachate can directly affect ground-water levels and
quality. Berms designed to withstand a 100-year flood and storm surge
will surround the entire gypsum storage and disposal site. Stormwater
falling on the bermed area will be directed to temporary storage areas
and allowed to percolate into the ground. None will be directly discharged
into any body of water. There should be no hydrologic impact on ground-
water flow.
Rainwater infiltrating through the gypsum to the water table is a potential
source of ground-water pollution. The permeability of the byproduct gypsum
produced by the proposed Unit 4 is guaranteed by the vendor of the FGD
system not to exceed 0.0002 foot per minute. The exact water quality of
the FGD system leachate at site will depend on site-specific factors.
Since the FGD byproduct will be gypsum, the major contributor to leachate
contamination is expected to be calcium sulfate. Ground water in the area
is typically high in sulfates; therefore, little impact is expected. There
are presently no Class I-B Florida water quality standards for calcium
sulfate, calcium, or sulfates.
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A recent study by the Electric Power Research Institute evaluated the effects
of storing FGD byproduct gypsum in an area of northern Florida very similar
to that of the Big Bend site. Results of a twenty-month monitoring program
revealed no evidence of significant degradation of ground-water quality
in either the surficial or Floridan aquifers.
Impacts of Particulate Control
Bottom ash will be collected in a water-filled bottom-ash hopper and hydrau-
lically sluiced to an earthen-diked pond. Overflow from the primary settling
pond will flow by gravity to a secondary settling pond, be clarified and
then be pumped back to the plant. The major portion of the bottom ash will
settle in the primary settling pond. Once this pond is filled, the ash
will be hydraulically dredged to an earthen-diked cell for final disposal.
Preliminary calculations using flow nets show that approximately 250 gallons
per minute of water will seep out of the bottom-ash pond into the surficial
aquifer. The analysis indicates that almost all of the seepage will occur
on the north, south, and west sides of the pond. Normal leakage at the site
area from the Floridan aquifer through the Hawthorn Formation into the sur-
ficial aquifer is estimated to be 0.0065 gallon per minute per acre. The
construction of the bottom-ash pond will reverse the hydraulic gradient in
the Hawthorn Formation so that 0.16 gallon per minute per acre will flow
from the surficial aquifer into the Floridan aquifer directly beneath the
pond. Leakage into the Floridan aquifer is predicted to be 0.013 gallon
per minute per acre for the area (10 acres) adjacent to the pond where the
water level will be raised in response to leakage from the pond into the
surficial aquifer. Maximum leakage directly beneath the pond into the
Floridan aquifer will be 0.29 and 0.13 gallon per minute from adjacent
areas where the ground-water table is raised. Total leakage into the
Floridan aquifer from the bottom-ash pond is predicted to be 0.42 gallon
per minute.
Seepage from the bottom-ash cells will result from rainfall percolation
through the material. Since the cell will be diked, rainwater in the dikes
will either evaporate or percolate into the ground; none will run off.
According to the hydrologic budget for Hillsborough County, approximately
40 percent of the rain falling into the cells will percolate into the ground.
Leachate from the bottom-ash-disposal area is not expected to have an adverse
impact on ground-water quality at the site.
The installation of a high-density polyethylene liner in the bottom-ash
pond would eliminate the seepage from the pond. Similarly, lined disposal
cells would not allow the percolation of rainwater through the ash into
the ground water. The estimated cost of liners for the pond and cells
is $2.1 million.
Unit 4 fly ash will be removed from the flue gas by electrostatic precipita-
tion, collected in hoppers, and pneumatically transported to silos for stor-
age and subsequent sale as a raw material for the production of portland
cement. At times when it may be impossible to market Unit 4 fly ash, an
ash-disposal system will be used. This system will also be used to dispose
of economizer ash and pyrites removed from the coal before combustion. The
solids will be sluiced from the plant to lined settling ponds. When the
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ponds reach the point at which they must be cleaned, a final earthen-diked
disposal cell will be constructed and lined.
Leachate from the fly-ash pond can directly affect ground-water levels and
quality. It is expected that the fly-ash pond will have minimal impact on
the ground-water system at the site because the pond will be sealed with a
liner having a very low permeability (0.0000001 centimeter per second).
Impacts of Once-Through Cooling Conventional Intake Screens for Unit 4
There are three principal concerns regarding potential impacts of once-
through cooling-water systems: (1) thermal effects due to the heated dis-
charge plume; (2) impingement (organisms being caught on the intake screens);
and (3) entrainment (organisms passing through the screens and then through
the cooling-water system).
Thermal Effects. The thermal impacts of Unit 4 on Tampa Bay were investi-
gated by TECO using a predictive mathematical model. The results of earlier
studies had shown that the surface area enclosed by the 2°C isotherm is
692 hectares when Units 1-3 are at 100 percent load (Figure 1-10). The
new study indicated that Unit 4 at 100 percent load would increase this
area to 720 hectares (Figure 1-11). Also, the surface area swept during
a tidal cycle by the 2°C isotherm would increase from 923 hectares to 983
hectares owing to the addition of Unit 4. Table 1-14 compares the pro-
jected temperatures of the Unit 4 effluent at the point of discharge with
the monthly ambient bay-water temperatures.
The operation of Units 1, 2, and 3 at 95 to 100 percent of their designed
capacity and without the use of a dilution-assist cooling system will have
an adverse thermal impact on approximately 30 hectares (74 acres) of benthic
habitat in Hillsborough Bay. Including the discharge canal (16 hectares
(40 acres)), a total of 46 hectares (114 acres) would suffer adverse environ-
mental impact from the thermal discharge.
With the addition of Unit 4 to the Big Bend power plant, the current heat
load to Hillsborough Bay is expected to increase by approximately 33 per-
cent. Although temperature rises at the point of discharge will remain
unchanged, the added thermal load to the bay will provide for an enlarge-
ment of the benthic area presently subject to adverse effects. Based on
a linear extrapolation, the operation of Units 1-4 without dilution-assist
cooling could potentially provide for an adverse impact to approximately
61 hectares (152 acres) of bay bottom.
The EPA concluded that the operation of Units 1-4 without a dilution-assist
cooling system will potentially have an adverse thermal impact on this area
of benthic habitat. The thermal impact, however, would not be viewed as
substantial or unacceptable in terms of thermal damage to the benthic biota
of Hillsborough Bay, because of the sandy, tide-swept nature of the benthic
area subject to the impact and the fact that this area does not represent
primary benthic habitat (i.e., seagrasses and other habitat-
forming features).
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Impingement. Studies were conducted at Big Bend Station during the periods
1976-1977 and 1979-1980 to determine the numbers of fish and invertebrates
impinged on the intake screens of Units 1-3. Projections of impingement
rates that would result from the addition of Unit 4 were also made. Based
on the Applicant's Section 316 Demonstration, EPA determined that adding
Unit 4 with conventional once-through cooling could increase existing
impingement effects by approximately 33 percent and that impingement
losses for four units are potentially adverse.
Entrainment. Several studies have also been conducted at the site to deter-
mine the extent of entrainment by Units 1-3 and to estimate the effects of
entrainment by Unit 4. Estimates were made of numbers of eggs and larvae of
selected representative important species that would be entrained annually
by Units 1-4 if conventional intake screens were used on Unit 4. These
estimates are based on abundance data collected during the 1979-1980 mero-
plankton studies. EPA determined that entrainment losses for four units
with conventional screens at Big Bend Station are potentially adverse.
Fine-Mesh Screens on Units 3 and 4
The potential thermal impacts of the Big Bend Station discharge plume would
be the same for this alternative as those described for conventional screens.
TECO constructed and tested a prototype fine-mesh-screening apparatus to
determine its efficacy as an intake device to reduce entrainment effects
associated with the operation of Units 1-4 with a once-through cooling
system.
The prototype device appeared to be approximately 56 percent effective
in screening eggs and larvae from source water. Suggested changes in the
design of the spraywash system, lifting buckets, and seals are proposed
as a means of substantially improving the screening efficiency of the in-
take device.
Fish eggs and invertebrate larvae collected from the fine-mesh screen
exhibited a low level of mortality. Many of the taxa involved were species
of sport and commercial value (e.g., stone crab and drum).
Fish larvae collected from the fine-mesh screens or by plankton nets for
control tests exhibited a high degree of mortality. The observed mortality,
however, cannot be concluded to be solely due to impingement effects of the
fine-mesh screen. Testing procedures (i.e., sampling and handling) can be
viewed as factors contributing to the apparent low survival of the larval
organisms. The immediate return of animals upon collection from the
screening device may enhance the survival of fish larvae.
The EPA determined that the placement of fine-mesh screening on the intake
structures of Units 3 and 4 will minimize entrainment effects, and, thus,
that the entrainment effects of Big Bend Units 1-4 will be approximately
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equal to the current impacts of Units 1, 2, and 3 using conventional intake
technology and no dilution pumps. Impingement effects will also be reduced
with this alternative. Accordingly, it is proposed that fine-mesh screens
be used on the intakes of Units 3 and 4 at Big Bend.
Fine-Mesh Screens on Units 1-4
The potential thermal impacts of the discharge of heated effluent from a
cooling-water system incorporating this alternative would be the same as
those of a conventional circulating-water system.
The numbers of organisms impinged and entrained as a result of the operation
of Units 1-4 with this alternative would be less than those attributable to
the operation of Units 1-3 with conventional screens. The feasibility of
backfitting fine-mesh screens to Units 1 and 2 has not been examined in
detail.
Dilution Pumping
A Section 316 Demonstration for Big Bend Units 1, 2, and 3, which at the
time included a dilution-assist cooling system, was evaluated by the EPA.
This evaluation revealed that the location and capacity of the station's
cooling-water facility were major factors in the unacceptable level of
entrainment. The Applicant responded with a proposal to terminate use of
the dilution-assist cooling system and to arrange for studies to assess
the thermal and associated biological consequences of such action.
Results of the thermal and biological studies were evaluated by the EPA.
The evaluation confirmed that a shutdown of the dilution-assist cooling
system at Big Bend Station would not cause an unacceptable thermal impact
on the aquatic resources of Hillsborough Bay. It also showed that such a
shutdown would effect a significant reduction in the pumping requirements
of the Big Bend facilities and would produce the expected reduction of
36 percent in entrainment. Based on these findings, the EPA has not
approved a dilution-assist cooling system for use with Unit 4.
Freshwater Use
The operation of Big Bend Unit 4 will have an indirect impact on the fresh-
water resources of the Tampa Bay area. Big Bend Station Units 1, 2, and 3
are presently served by the Hillsborough County South/Central Water System
for its average freshwater need of 1.1 million gallons per day. The oper-
ation of the proposed Big Bend Unit 4 will require an additional 2.1 million
gallons per day of freshwater. Big Bend Station will rely on Hillsborough
County to meet the additional freshwater demand of Unit 4. The County is
in the process of studying its water systems and has included Big Bend
Unit 4 in its long-range plans.
The design of Big Bend Unit 4 will include an expansion of the existing
recycling system, permitting significant savings of freshwater. Records
show that the use of recycled water at the existing facility has cut potable
water consumption by 21-23 percent.
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Wastewater Treatment Systems
Through the NPDES permitting process, water quality standards and standards
of performance for new sources are applied to control the quantity and/or
quality of the discharge of liquid effluents. Florida water quality standards
are also applicable.
During the construction of Big Bend Unit 4, there will be two discharges
associated with the installation of the circulating-water line: (1) con-
struction dewatering discharge into the plant intake canal (NPDES No. 012)
and (2) construction dewatering discharge into the plant discharge canal
(NPDES No. 013). The point of discharge of No. 012 will be the eastern
end of the intake canal. The point of discharge of No. 013 will be west
of the Unit 3 condenser cooling-water discharge (NPDES No. 004), so that
dewatering pumpage is not pushed into Jackson Branch during a rising tide.
Since Big Bend Station and the construction site are surrounded on three
sides by the waters of Hillsborough Bay (including the intake and discharge
canals), the quality of the surficial ground water at the circulating-water-
line excavation (i.e., that water subject to construction dewatering) is
estimated to be similar to that in the intake and discharge canals.
There will be no discharge associated with the construction of the Unit 4
building and related facilities. Surface runoff will be intercepted and
pumped to the wastewater-treatment pond.
Discharges from the operation of Unit 4 will include (1) once-through-
cooling water (NPDES No. 008) or condenser cooling-tower blowdown, depend-
ing on which cooling alternative is selected; (2) boiler blowdown (NPDES
No. 009); (3) bottom-ash-system blowdown (NPDES No. 010); and (4) FGD-system
blowdown (NPDES No. Oil). A schematic of the plant water flow during the
operational phase is presented in Figure 1-5.
Table 1-15 lists the continuous discharge streams, their expected contami-
nants, and the estimated concentrations of these contaminants. The combined
effluents are the bottom-ash blowdown, the boiler blowdown, the FGD bleed
stream, and the once-through cooling-water discharge. The FGD-blowdown
stream (70 gallons per minute) will be treated to remove suspended solids
and to adjust the pH to meet applicable effluent limitations. The bottom-
ash-sluice system (80 gallons per minute) will allow for the settling of
suspended solids before the discharge of blowdown. Boiler blowdown (30 gal-
lons per minute) will not require treatment to meet effluent limitations.
These three streams will be combined with the circulating water (241,200 gal-
lons per minute) a minimum of 350 feet upstream from the point of discharge
to provide for complete mixing prior to discharge.
A review of the available water quality data indicate that during various
periods of time the concentrations of arsenic, cadmium, chromium, copper,
iron, mercury, nickel, and selenium in the ambient intake water exceeded
the quality standards. In view of the fact that the concentrations of
certain of the above elements in the ambient water often violate water-
quality standards, TEC0, on April 13, 1981, applied for a variance from
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those applicable water-quality standards to allow the discharge in Hills-
borough Bay of the combined-waste stream from Big Bend Unit 4. This vari-
ance has been granted for a two-year period.
Predicted water quality data for Big Bend Unit 4—individual streams as
well as the combined-discharge stream—is provided in Table 1-16. The
data show that there will be no detectable change in water quality between
the intake and the point of discharge. Although it is possible to calculate
very minor variations in the combined-discharge stream, these variations
cannot be measured. This prediction is based on complete mixing within
350 feet of circulating-water line prior to release in the discharge canal.
In support of the variance request, TECO considered alternative treatments
of the discharge streams to remove heavy metals, assuming the individual
streams could be treated to meet water-quality standards prior to mixing
with the circulating water. The cost of such treatment was estimated as
$1.2 to $1.8 million (1985 dollars), depending on the treatment method
selected. The estimated water quality of the blowdown streams after further
treatment to remove heavy metals is provided in Table 1-17.
A value of 0.2 milligram per liter has been identified as the limiting con-
centration for total residual oxidants (TRO) at the point of discharge. The
rationale for this concentration is as follows:
1. Discharge limitations rarely exceed 0.2 milligram per liter.
2. The 96-hour LCjq data provided by TECO and other data available
indicate that 0.2 milligram per liter falls within the range of
tolerance for most organisms that could occur in the area.
3. Most of the affected organisms tested were juvenile. Generally,
adult organisms can tolerate higher concentrations of chlorine,
and adult species are more likely to be in the discharge canal;
therefore, 0.2 milligram per liter was chosen even though it is
near the upper limit of the effects range.
4. Since the discharge canal is thermally stressed and has a posi-
tive discharge flow that tends to reduce the number of juvenile
organisms present, a 6.1-acre mixing zone for chlorine should
not have significant adverse effects.
It is expected that this limit would not be exceeded outside of the proposed
6.1-acre mixing zone.
All inplant freshwater waste streams, both continuous and intermittent, are
captured by the inplant collection system and conveyed to the wastewater-
treatment ponds. The treatment of the wastewater is limited to the removal
of settleable solids within the settling basins and self-neutralization
within the system of ponds. A spray-irrigation system provides for land
application and disposal of that portion of the wastewater within the reten-
tion pond in excess of the demand for recycled wastewater at the plant.
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It is estimated that 300 gallons of water per minute seep out of the bottom
of the wastewater pond into the unconfined aquifer. Approximately 0.48
gallon per minute leaks through the unconfined aquifer into the Floridan
aquifer. Any increase in this seepage will cause the ground-water level
in the unconfined aquifer to rise in the vicinity of the pond, thereby
forming a ground-water mound.
The spray-irrigation rate is governed by pond level, seasonal conditions,
and ground-water level. The overriding criterion for system operation
is the avoidance of runoff from the sprayed area. When runoff is not a
limiting condition, application rates of from 2 to 4 inches per week are
common. This provides ultimate water disposal ranging from 254,400 to
508,800 gallons per day. It is conservatively estimated that approximately
36,000 gallons per day of recharge has been added to the normal recharge
rate at the field as a result of the spray-irrigation operation. Conse-
quently, a ground-water mound has been formed beneath the spray-irrigation
field.
Certain waste streams from Big Bend Unit 4 will be channeled to the waste-
water pond and sprayfield system currently used for the treatment of
effluents from Units 1-3. The ground water at the Big Bend site has been
designated as Class I-B in accordance with Florida water quality standards.
Data on the wastewater pond and sprayfield system indicate that average
concentrations of chromium, selenium, and mercury and maximum concentra-
tions of arsenic and cadmium could exceed ground-water-quality standards.
There are no data for lead concentrations, since the limit of detection
for the lead test method is greater than the Florida water quality standards.
Routing of these wastes to surface waters rather than allowing them to
percolate into the ground water is possible. Such treatment, however,
could increase the concentrations of the above elements in surface waters.
The potential potable water supply at the Big Bend site is the underlying
Floridan aquifer. It is conservatively estimated that less than one-half
gallon per minute will seep into the Floridan aquifer as a result of the
operation of the existing wastewater-treatment system; hence, no impact
on the water quality of the Floridan aquifer is expected. Moreover, the
general direction of flow in the Floridan aquifer at the Big Bend site is
westerly. Any well downstream of the wastewater-treatment system would have
to be located between the treatment facilities and Hillsborough Bay on prop-
erty owned by the Applicant. TECO has withdrawn the request for a variance
from Florida water quality standards for some discharges from the waste-
water pond and sprayfield system and Florida DER has designated the zone
of discharge to the ground water from these sources as the area within the
Big Bend site boundries.
The plant complex is situated on dredge fill consisting typically of highly
permeable sand and shell material. Storm runoff can cause site flooding
and could transport pollutants to surface waters. Storage areas for oils,
greases, and other petroleum hydrocarbons will be constructed so that spil-
lage from these areas will not contaminate the stormwater.
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1.3.3.4 Impacts of Cooling Towers
All types of wet-mechanical-draft cooling towers considered for Unit 4
will have similar impacts on the biota of the region, but the impacts on
local water resources will vary according to the source of makeup water.
The potential impacts of the thermal discharge would be the same for the
mechanical-draft cooling-tower alternatives evaluated regardless of the
source of makeup water. The impact of the thermal plume resulting from
the discharge of blowdown from the mechanical-draft towers will be much
less than that associated with the once-through cooling alternative. No
detectable change in the size, shape, or temperature of the plume from
Units 1-3 is expected as a result of the operation of a cooling tower for
Unit 4.
The numbers of organisms impinged upon or entrained by the makeup-water
intake for saltwater towers would be very small because of the volume of
flow (about 24 cubic feet per second) and its location in the discharge
canal. If the makeup intake were located in the intake canal, some in-
crease in the numbers of organisms lost would result; however, the losses
would still be quite small compared to those that would result from a once-
through-cooling system. There would be no impingement or entrainment impacts
if treated wastewater or brackish water were used for makeup.
Another issue of concern is the potential impacts of the cooling-tower
alternatives on water resources. A ground-water investigation was con-
ducted to evaluate the availability of brackish artesian water as an
alternative source of cooling-tower makeup.
Further investigations would be necessary before conclusions can be reached
as to the feasibility of the brackish water as a makeup source and the
environmental effects of pumping such water from the aquifer. The quanti-
ties of freshwater needed for a closed-cycle system would place a great
burden on the local ground-water resources. For this reason, efforts have
concentrated on finding a feasible source of treated sewage effluent.
1.3.4 HUMAN FACTORS
1.3.4.1 Demography, Land Use, and Aesthetics
Baseline Conditions at Big Bend
The proposed site for Big Bend Unit 4 is approximately 10 miles south of
the city of Tampa and 5 miles north of Ruskin, in Hillsborough County.
The estimated population of Hillsborough County in January 1977 was 655,600,
a 33.7 percent increase over the 1970 population and a 64.8 percent increase
over the 1960 population. By 2020 the county population is projected to
increase to over 1.1 million.
The population center nearest to the plant site is Apollo Beach, which is
just 1 mile to the south. In addition, the towns of Adamsville and North
Ruskin are within 5 miles. Ruskin, south of the site on the edge of the
5—mile radius, is the only other population center within 5 miles. Several
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new residential subdivisions have been developed within 5 miles of the site
since 1960. Population growth is projected to occur along the shoreline,
along major highways, and around Gibsonton and Ruskin. The Horizon 2000
Plan calls for residential development at a density of between 2.6 and 7.5
dwelling units per acre in the area just south of Big Bend Road and west of
U.S. 41. Much of the region south of Big Bend Road and east of U.S. 41 is
projected to remain rural. Currently, Big Bend Station and the associated
facilities are zoned industrial.
Big Bend Station is located in a primarily rural area on the eastern shore
of Hillsborough Bay. Much of the area's agricultural land is used for pas-
ture. Swamps, flood-prone areas, and ecologically sensitive coastal waters
limit residential development of the area immediately adjacent to the site.
Six parks and three recreational areas are located within 5 miles of the
site. Hillsborough County established these parks for the protection of
animal and plant life as well as for recreational purposes.
No sites presently listed in the National Register of Historic Places or
the Registry of Natural Landmarks occur within 5 miles of the Big Bend site.
A cultural assessment of the area proposed for Big Bend Unit 4 and the associ-
ated facilities was conducted in 1979. A review of the Florida Master Site
File revealed no archaeological or historic sites or properties within the
tracts under investigation. Assessment data also led to the conclusion that
the proposed development in all probability would not affect any sites listed
or eligible for listing on the National Register of Historic Places.
Impacts of Construction Activities
It is estimated that an average of 514 construction workers (craft and non-
manual) will be required per year during the 3-year construction periods. A
peak-construction labor force of approximately 980 persons will be needed for
approximately 2 months during 1984.
A survey of local union representatives has indicated that most of the crafts-
men will be from Tampa and the surrounding communities, supplemented by people
from other areas during peak periods. At the peak of construction, approxi-
mately 98 construction workers are expected to migrate into Hillsborough
County.
If it is assumed that each of these workers brings a family, the total number
of persons relocating to the Tampa area as a direct result of construction
will be 294, or less than 0.05 percent of the 1979 estimated total population
of Hillsborough County. Plant construction is not expected to have an impact
on local communities except for intermittent traffic congestion. Plant con-
struction is also expected to have a negligible effect on nearby recreational
facilities, in view of the previous commitment of the site and adjacent areas
to industrial land use.
According to the Hillsborough Horizon 2000 Plan, Big Bend Station will be a
heavy industrial area by the year 2000. Immediately adjacent lands on the
north, east, and southeast have been designated for industrial use. Swamps
and flood-prone areas within 5 miles of the site are expected to limit future
development, however. Unit 4 is thus consistent with current and projected
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land-use patterns and practices, and it is generally expected that it will
not adversely affect the land use of the area.
The construction of Big Bend Unit 4 will not cause a relocation or direct
physical disturbance of any historically or culturally significant features
in Hillsborough County.
The aesthetic quality of the site and surrounding area will not change dra-
matically during construction. Currently, 80 percent of the Big Bend site
has been influenced by human activity. The area's landscape is dominated by
the existing structures on the site. The additions will not significantly
increase the visual or aesthetic impact of Units 1, 2, and 3 because of the
size of the existing structures and the compatibility of the proposed unit
with the industrial nature of the area.
Indirect impacts associated with Unit 4 construction will include the de-
mands placed on the area by the relocation of construction workers. As the
number of relocating workers is expected to be small, the induced demands
and the indirect impacts on demography, land use, and aesthetics are not
expected to be significant.
Impacts of Operation
The aspects of the operation of Unit 4 that could have an impact on demog-
raphy, land use, and aesthetics are those related to the air-pollution-
control systems.
The development of the FGD-waste-disposal areas is expected to have a long-
term visual impact. The planting of vegetative screening around its periph-
ery will effectively screen the fill from most viewing areas. In addition,
upon reaching fill capacity, each parcel will be revegetated with native
plant species to minimize the visual impact of the area. At the end of the
life of Unit 4, it is expected that the disposal area will be dedicated to
use as public open space.
The aesthetic impact of the fly-ash-disposal area is similar to that of the
FGD storage and disposal area.
Impacts of Cooling Towers
Unlike once-through cooling options, the use of a cooling tower with salt-
water makeup would require additional land area. Aside from the visibility
of the drift plume, the aesthetic impact of the saltwater cooling tower
should not be significant. In addition, salt drift from the towers could
limit the agricultural use of adjacent land to only those crops that are
not salt-sensitive.
A freshwater or brackish water cooling tower would be expected to have the
same dimensions as a saltwater cooling tower, and thus the same commitment
of land resources and similar aesthetic impacts. The use of freshwater or
brackish water makeup, however, would minimize salt deposition on adjacent
and nearby agricultural vegetation.
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1.3.4.2 Socioeconomics
Baseline Conditions at Big Bend
Total personal income in Hillsborough County rose from approximately $1.69
billion in 1970 to over $3.5 billion in 1977, while the per capita income
rose from $3,416 to $6,145. Per capita income in the Tampa-St, Petersburg
Standard Metropolitan Statistical Area (Hillsborough and Pinellas Counties)
is projected to increase to $12,100 by the year 2020. This rate of increase
is greater than that projected for the United States but lower than the
projection for the State.
The county's labor force averaged 272,519 persons in 1978. The unemployment
rate for the year was 5.5 percent, which compared favorably with the State's
unemployment rate of 6.6 percent and the national rate of 6 percent. Employ-
ment is projected to increase by about 50 percent over the 1980-2020 period,
reaching a total of 755,400 persons. Population gains are forecast to out-
strip the expansion in employment during this same period, growing over 77
percent by 2020.
The majority of the county's workers are employed in the nonmanufacturing
sectors, which consist of agricultural services and forestry; contract
construction; transportation, utilities, and communications; trade (whole-
sale and retail); finance, insurance, and real estate; services; mining;
and civil government. Of these industries, trade employs the most workers,
followed by services and manufacturing. In 1977, manufacturing contributed
$380,322,000 to the county's total annual payroll of $1.8 billion. Other
major contributing business sectors were retail trade services and
transportation.
During the 1977-1978 fiscal year, total revenues accruing to the local gov-
ernments within Hillsborough County amounted to $410,202,864. This figure
includes the revenues of Plant City ($7,396,653), Temple Terrace ($9,456,878),
Tampa ($161,824,626), the Hillsborough Industrial Special District
($57,747,618), and Hillsborough County itself ($173,777,089). Taxes were the
source of over 24 percent of the total revenue collected within the county
during 1977-1978. Of the total revenue, 77 percent was raised from property
taxes, 15 percent was from utility services taxes, and 8 percent was from
franchise taxes.
Hillsborough County's total housing stock rose from 81,000 units in 1950
to approximately 234,000 units in 1976. From 1976 to 1978, 10,909 single-
family units and 4,251 apartment units were added to the county's housing
stock. About 13,000 of the county's 1976-1977 total of 234,000 housing
units were vacant. The majority of these vacancies were among multifamily
units. The average vacancy rate for all multifamily units was 11 percent.
Impacts of Construction Activities
An estimated $11,800,000 (expressed in 1982 dollars) will be paid to con-
struction personnel over the 3-year construction period. Of this total,
an estimated $10,018,200 (1982 dollars) will constitute disposable income.
The expenditure of most of this money in the Tampa area will substantially
benefit the local economy.
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Since the relocation of construction workers and
produce only a small increase in the overall demand ^*ousingan
munity services, no special provisions for housing, education, or
nity facilities are expected.
Local taxoavers are expected to predominate among construction workers
Local taxpayers are y oprvices. Moreover, taxes on
using community roads, schools, and health se .jjit-i/mai
Big Bend Unit 4 »U1 cooipei,»ateHinsboroUghC„uny or truction
for Unit 4 will be approximately $3,700,000.
The employment ot a daily average of approximately 514
over the 3-year construction period for Unit 4 wi av workers
creasing the demand for goods and services in the areas , effect"
spend their wages and salaries. This change wil d ser_
in that new jobs will be created to provide the additional goods and ser^
vices. The magnitude of this multiplier effect may e in ® and'oeak
ever, since (1) the limited duration of the overall construction an.i peak
construction work periods—3 years and 2 months, respec lve y
courage capital-intensive investment to meet service email s>
percent of the construction workers are estimated to resi e wi
region and may be presumed to be already contributing to ^ e ov -verv
ice demands of the region. Assuming a maximum of 75 service j ,
100 construction employees, 386 construction-induce jo s wi
The spending of disposable income during the construction Pe"-od will
have a multiplier effect, since those receiving the dollars that the
workers spend will respend a portion of their income in e are®* ...
induced employment, however, the magnitude of this mu tip ler e e .
be tempered by the limited duration of the overall construction an p
construction work periods.
Impacts of Operation
The operational impact of Big Bend Unit 4 on socioeconomics will be attrib-
utable mainly to the air pollution control systems.
Both the capital and annual costs of TECO's proposed wet-limestone-scrubbing
system are lower than those of alternative sulfur-dioxi e con ro sys
considered, except for the lime-FGD system, provided that a gypsum-grade ma
terial is produced and marketed. Assuming capital and annual costs of th
sulfur-dioxide-control technology are indicative of Cl) the revenue po e -
tially derived through taxes on the facility and (2) the annual demand for
labor, supplies, and services, the proposed sulfur-dioxide-contro sys em
would result in a comparatively small economic loss to the local economy.
This loss could be more than offset, however, by the development and sale
a gypsum-grade material.
Of the alternative sulfur-dioxide-control technologies, the wet-limestone-
scrubbing system has the least water requirements. Approximately 1.1 mi
lion gallons per day of makeup water will be required for the proposed
system. Current plans are to use water from the Hillsborough County Sout
Central System. In order to minimize the demand on this municipal system,
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TECO has been included in the Hillsborough County South 201 Facility Plan
for the reuse of sewage effluent. According to this plan, 1.3 million
gallons per day will be made available for Big Bend in 1986.
The fly ash produced through the use of an electrostatic precipitator can
be sold as a raw material for the production of cement. The marketability
of the fly ash for cement production is sensitive to the economic condi-
tions within the area and the need for additional construction. The sale
of fly ash as a raw material is considered a source of indirect economic
benefit to the area.
Impacts of Cooling Towers
The main socioeconomic implications of a decision to use mechanical-draft
cooling towers with saltwater makeup are (1) economic growth associated
with the construction of additional plant facilities and (2) damage to
nearby agricultural vegetation as a result of salt deposition. Cooling
tower construction would contribute to the economic vitality of the region
by virtue of the increased property tax levy on Big Bend Station as well
as the influx of additional construction personnel. This economic benefit
could be offset, however, by a loss in local agricultural productivity
as the result of salt deposition.
Cooling towers with treated wastewater makeup would be of greater economic
benefit to the region than those with saltwater makeup, since a pipeline
would have to be constructed to transport treated wastewater to Big Bend
Station. The construction of this pipeline would require the hiring of
additional construction workers.
In contrast with the saltwater-makeup cooling tower, this alternative would
result in much less potential damage to agricultural vegetation by salt
deposition. This advantage could be offset, however, by economic problems
related to the logistics of pipeline construction.
1.3.4.3 Transportation
Baseline Conditions at Big Bend
Federal, State, and county highways are the primary transportation arteries
in Hillsborough County. In the southern half of the county, the only pri-
mary highways are U.S. 41 and U.S. 301, both of which parallel the Tampa
Bay coastline. These routes pass east of Big Bend Station at a distance
of 1.5 and 4 miles, respectively.
In the Horizon 2000 transportation circulation plan, the county has pro-
jected an extension of 1-75 to the south. Upon completion of the extension,
this four-lane expressway will run between U.S. 41 and U.S. 301 and will
pass approximately 2-2/3 miles east of Big Bend Station. U.S. 41 and Big
Bend Road provide auto and truck access to the plant site.
As with highways, railroad tracks in the southern half of Hillsborough county
are limited, and only two stretches of track, running in a north-south direc-
tion, connect the county with its southern neighbor, Manatee County. One of
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these two tracks passes 1.5 miles to the east of Big Bend Station, and spurs
from this line serve the station.
The Port of Tampa is the eighth largest port in the United States. The major
commodities flowing through it are phosphate rock, petroleum, and sulfur.
General cargo accounted for only 3 percent of the total tonnage in 1978 and
for 24.4 percent of the port's economic value. The total tonnage passing
through the port increased from 41.5 million tons in 1974 to over 48 million
tons in 1978. Total tonnage is projected to reach 70 million tons by 1990
and 97 million tons by the year 2000 and port facilities will have to be
upgraded and expanded to accommodate the additional tonnage.
Impacts of Construction Activities
The most significant impact associated with the construction of Unit 4 will
be the movement of workers, materials, and equipment to and from Big Bend
Station. Most of the traffic will access the station from the north via
U.S. 41. An average of 1100 vehicles per day (550 in each direction) will
use the site during the peak-construction period in 1984. Of these 550
vehicles, an estimated 516 will be employee vehicles, 12 will be visitor
vehicles, and 22 will be trucks.
U.S. 41 will generally be able to accommodate the additional construction-
related traffic. During the morning and evening periods of peak traffic
flow, however, intermittent traffic congestion may occur at the intersection
of Big Bend Road and U.S. 41, and in the residential development of Adamsville.
The community of Apollo Beach may also experience periodic traffic congestion
because of its proximity to the site.
Construction materials will be transported to the site by truck, rail, and
barge. As with truck transportation, the impact of rail and barge transpor-
tation is considered to be negligible.
The existing Big Bend Port can accommodate additional barges. The deepening
of Big Bend Channel to as much as 43 feet is currently under study by the
U.S. Army Corps of Engineers.
Impacts of Operation
The operational impact of the proposed unit on transportation will be pri-
marily in the areas of coal handling, sulfur dioxide control, and particu-
late control.
The existing Big Bend Units 1, 2, and 3 burn coal delivered to the site by
barge, as will Unit 4. No modifications to the dock or to the unloading
facilities are contemplated in connection with the construction of Unit 4.
The total annual fuel requirement for Unit 4 is estimated to be 950,000 tons.
The additional barge traffic required to supply fuel for Unit 4 will amount
to less than one delivery per week, with an average shipment of approximately
25,000 metric tons.
If the gypsum byproduct of the FGD process is marketed commercially, approxi-
mately 210,000 tons of this byproduct may be transported from Big Bend Station
to a local wallboard-manufacturing concern. If 10-ton trucks are used for the
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continuous shipment of gypsum to a local manufacturer, approximately 66 truck
shipments per day will take place. While this volume of offsite truck traffic
will not have a significant impact on the area's transportation network, the
continuous shipments could cause intermittent traffic congestion, and, depend-
ing on shipment procedures and routes, could add to the problem of localized
dust and noise.
The major offsite transportation impact attributable to the use of the par-
ticulate-control system will be the shipment of fly ash for sale as a raw
material in cement production. Given an annual production rate of 102,400
tons from Unit 4, and the use of 10-ton trucks for continuous shipment, a
maximum of approximately 29 truck shipments per day will be required. The
combination of these 29 shipments and the estimated 66 shipments of FGD by-
product gypsum (a total of 95 trucks per day) will not overtax the existing
transportation network, but occasional local traffic congestion and addi-
tional dust and noise can be expected.
Impacts of Cooling Towers
All of the cooling-tower alternatives considered in detail have a potential
for the generation of localized fogging under certain atmospheric conditions.
Given the distance of the station from the nearest major highway facility
(i.e., U.S. 41, approximately 1.5 miles to the east), however, the poten-
tial for fogging of a major thoroughfare appears to be very limited.
Impacts of Once-Through Cooling-Water Systems
All alternative once-through cooling-water systems are equivalent in their
potential for fogging. In the absence of detailed information, it may be
assumed that the potential for additional fogging due to Unit 4 is slight,
and that in all probability fogging would affect only water transportation
in and around the station. The once-through systems would produce less
fogging than would cooling towers.
1.3.5 SENSITIVE SPECIES, HABITATS, AND AREAS
1.3.5.1 Baseline Conditions at Big Bend
Special-Status Species (Wildlife)
A number of special-status species reportedly use the Big Bend site and
vicinity, and these species could be affected by the construction and oper-
ation of the proposed Unit 4. Those species listed by the U.S. Fish and
Wildlife Service as endangered or threatened are identified below. Informa-
tion on Florida special-status species (endangered, threatened, rare, and of
special concern), as designated by the Florida Game and Fresh Water Fish Com-
mission and the Florida Committee on Rare and Endangered Plants and Animals,
is presented in Table 1-18.
Brown Pelican (Federal status! endangered; Florida status: threatened).
Brown pelicans have been regularly observed flying near the site and feed-
ing near the mangrove swamp south of the discharge canal. They are expected
to occur in the vicinity on a daily basis owing to the presence of at least
two county rookeries. No brown pelicans are believed to nest at the site.
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Southern Bald Eagle (Federal status; endangered; Florida status; threat-
ened) . Bald eagles have not been observed on the site, but several pairs
regularly nest in Hillsborough County and wandering or hunting individuals
could occasionally use shore and aquatic habitats at Big Bend.
West Indian Manatee (Federal status; endangered; Florida status: endan-
gered) . There are two habitats designated as critical for the manatee in
the area of Big Bend: the Alafia and Little Manatee Rivers. Individuals
have also been frequently reported elsewhere along the eastern shore of
Tampa Bay. In a study sponsored by the Applicant, the Big Bend power station
ranked second in importance to the Gardinier Phosphate Plant on the Alafia
River as a warm-water refuge in the area. As many as 10 individuals have
been observed at one time in the Big Bend discharge canal.
Sea Turtles (Federal status: endangered; Florida status: endangered). No
sea turtles have been reported on or near the site during the biological sur-
veys conducted by the Applicant. Each of the four species (Atlantic logger-
head, Atlantic green, Atlantic leatherback, and Atlantic Ridley) may occur
rarely near the site in Tampa Bay. None of these species is expected to
nest at the site.
Peregrine Falcon (Federal status: endangered; Florida status: endangered).
This species can be expected to occur as a very rare migrant. It may use
beach areas and mangrove swamps along the Tampa Bay shoreline to prey on
shorebirds.
Eastern Indigo Snake (Federal status: threatened; Florida status: threat-
ened ). Two individuals of this species were observed during field surveys
on the site in the Myrica-Baccharis association. This species is expected
to use this and possibly other habitats on the site for breeding, food, and
cover.
American Alligator (Federal status: threatened; Florida status: species
of special concern). No alligators have been observed on the site, although
they have been reported elsewhere along the eastern shore of Tampa Bay. The
preferred habitats of this species (large freshwater bodies, swamps, and
marshes) do not occur on the site, but alligators could use the brackish
habitats along the edge of the mangrove swamp as well as the ditches and
small ponds found in the area.
Sensitive Habitats
Two sensitive habitats can be identified on or near the site: mangrove swamp
and seagrasses.
Mangrove Area. A mangrove comnunity forms a distinct vegetational zone along
the southwestern coastal portion of the site where tidal flushing occurs.
This is the oldest and least disturbed plant community at the site. It con-
tains three arborescent species: the white, red, and black mangrove. Stands
of mangroves have several important ecological roles: they produce organic
matter in great quantity, by accumulating sediment they extend and protect
coastlines, and they provide protection and habitat for other plants and
animals.
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Seagrasses. It has been estimated that benthic seagrasses and associated
macroalgae cover approximately 21,000 acres on the bottom of Tampa Bay. How-
ever, surveys conducted for the Applicant in the vicinity of Big Bend indi-
cate that seagrass coverage is limited in this area. Only one seagrass spe-
cies (Ruppia maritima) was found in the embayment area south of the discharge
canal, and both coverage and density were very low. A second area near the
former dilution pump intake contained sparse growth of Halodule wrightii
during some periods of the year.
1.3.5.2 Impacts of Construction
Special-Status Species
The only special-status species that could be affected by construction activ-
ities is the indigo snake. It is expected that the commitment of about 218
acres of the site to the ash ponds and the gypsum storage and disposal area
could result in the loss of habitat for this species. Further loss of habitat
would occur if a cooling tower is constructed at Big Bend.
No alligators have been reported at the site. Accordingly, the loss of the
small wetland areas and the rerouting of Jackson Branch are not expected
to affect this species since these habitats are presently only marginally
suitable for alligators.
Sensitive Habitats
The construction of the intake and discharge structures will affect only
small areas in the intake and discharge canals. No impact is expected on
the limited areas of seagrasses in the vicinity of the site.
The layout for the proposed generating unit has been planned in such a man-
ner that the mangrove areas will not be affected by construction activities.
If cooling towers are required, they will be located near the mangrove areas.
However, their placement could be such that impacts on the mangroves will
be minimized.
1.3.5.3 Impacts of Operation
It is anticipated that no special-status species will be adversely affected
by the operation of Unit 4. The U.S. Fish and Wildlife Service, during for-
mal consultation on the project pursuant to Section 7 of the Endangered Species
Act, has concurred with this conclusion.
There is a possible beneficial effect of adding a fourth unit with once-
through cooling at Big Bend Station: the potential for cold shock to mana-
tees as a result of station shutdown would be reduced. The probability of
a simultaneous shutdown of four generating units is lower than that of a
similar shutdown of only three.
The only sensitive habitat that could be affected by this system is the man-
grove area. Leachate from the unlined bottom-ash pond will enter the ground
water and migrate toward the Bay. There is not sufficient information avail-
able to determine if this leachate can be taken up by the mangrove trees
or if it will adversely affect them.
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1.3.5.4 IMPACTS OF COOLING TOWERS
Special-Status Species
Potential impacts to special-status species from cooling-tower operation
include the collision of the three bird species with the structure, habitat
loss for the indigo snake and the alligator, and the effects of increased
noise levels on all of the species.
Sensitive Habitats
The preemption of land for the cooling tower may affect the sensitive man-
grove area and associated marshes. The tower could be located in such a way
as to minimize any impact on this area.
In the case of brackish-water cooling towers, the withdrawal of makeup water
from deep artesian aquifers may affect the quality and quantity of fresh
water in shallow artesian aquifers. This, in turn, may affect vegetation
in sensitive habitats on the site.
The use of freshwater cooling towers could also affect sensitive areas. It
is expected that freshwater withdrawal for makeup will seriously overburden
local ground-water resources, which will in turn affect vegetation in sensi-
tive habitats on the site. Accordingly, sources of sewage effluent to serve
as cooling-tower freshwater makeup have been investigated.
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Table 1-6. National and State of Florida ambient air quality standards applicable to
the proposed site, Hillsborough County, Florida
National®
Pollutant
Averaging time
Primary standard
Secondary standard
Florida11
Suspended particulate matter
Annual geometric mean
24-hour maximum
75 Ug/m3
260 yg/m3
60 pg/m3
150 yg/m3^0)
60 yg/m3
150 yg/m3(c>
Sulfur dioxide
Annual arithmetic mean
24-hour maximum
3-hour maximum
80 yg/m3
365 ng/m^Cc)
NA
NA
NA
1,300 M«/m3(c)
60 yg/m3
260 yg/m3
1,300 yg/m3(c)
Carbon monoxide
Hydrocarbons
8-hour maximum
1-hour maximum
3-hour maximum
(6 to 9 a.m.)
9 ppmc
35 ppmc
0.24 ppmc
9 ppmc
35 ppmc
0.24 ppmc
\
9 ppmc
35 ppmc
0.24 ppmc
Nitrogen dioxide
Annual arithmetic mean
100 yg'/m3
100 yg/m3
100 yg/m3
Ozone
1-hour maximum
120 ppbc
120 ppbc
80 ppbc
g/ra3 = micrograms per cubic meter.
NA = not applicable,
ppm = parts per million,
ppb = parts per billion.
aCode of Federal Regulations, Title 40, Part 50, 1976, and FDER (1972).
^Florida Administrative Code, Chapter 17-2.
Concentration not to be exceeded more than once per year.
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Table 1-7. Federal and State of Florida prevention of
significant deterioration allowable increments
(micrograms per cubic meter)
Pollutant/averaging time
I
Class
11
III
Particulate matter
Annual geometric mean
5
19
37
24-hour maximum®
10
37
75
Sulfur dioxide
Annual arithmetic mean
2
20
40
24-hour maximum®
5
91
182
3-hour maximum®
25
512
700
aIncrement can be exceeded once per year.
Table 1-8. Maximum air-quality impacts (micrograms per cubic meter)
at the Big Bend site with Unit 4 operating
Annual
24-hour®
3-hour
Case
S02 TSP
S02
TSP
so2
Attainment-area impacts
Big Bend Unit 4 only
<1 <1
34.2
0.9
163
Big Bend Units 1-4
8.5 0.2
185
3.7
1087
With all interacting
18.5 69.2b
sources
82
128.lc
992
State of Florida AAOS
60 60
260
150
1300
Nonattainment-area
impacts^
Big Bend Unit 4 only
<1 <1
4
0.4
17
Significance-of-
impact level
1 1
5
5
25
Abbreviations:
SO2 ¦ sulfur dioxide.
TSP ¦ total suspended particulates.
AAQS ¦ ambient-air-quality standard.
aNot to be exceeded more than once per year.
^Includes background concentration of 35 micrograms per cubic meter.
Modeling violation only.
clncludes background concentration of 55 micrograms per cubic meter.
^Sulfur dioxide impact at Pinellas County nonattainment area and impact
of total suspended particulates at Hillsborough County nonattainment
area.
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Table 1-9. FDER prevention of significant deterioration maximum
increment consumption (micrograms per cubic meter)
at the Big Bend site
Annuala 24-hour^ 3-hour^
Case S02 TSP SO2 TSP SO2
Big Bend Units 1-4
only 0.0 0.0 -4.4 0.3 67.7
With all inter-
acting sources
Projected 8.0 34.3 20.3 3.7 824.1
Baseline 21.0 10.0 24.7 0.0 756.4
Increment
consumption -13.1 24.3^ -4.4 3.7 67.7
EPA allowable
Class II incre-
ment 20 19 91 37 512
Abbreviations:
FDER ¦ Florida Department of Environmental Regulations.
SO2 ¦ sulfur dioxide.
TSP ¦ total suspended particulates.
EPA ¦ U.S. Environmental Protection Agency.
aIncludes all sources within a 50-kilometer radius.
^Includes all sources within a 15-kilometer radius plus other major
sources.
cModeling violation only.
Note: Minus values indicate air-quality improvement.
1-73
-------
Table 1-10. Water-quality data for Hillsborough Bay, Florida3'1*
Parameter
I972c
Annual average
ibient concentration
1978d
1979*
Florida
Class III
water standard^
Average
composition
of seawaterS
Alkalinity, total
102.4
Biochemical oxygen demand
1.8
3.1
2.9
Calcium
335
413
Chloride
15,880
<0.05h
19,353
Chromium (total)
<0.01
Color (platinum color units)
8.5
13.3
17.1
Conductivity (ymhos/cm)
37,510
39,535
39,258
Copper
<0.01
<0.015
<0.002
Effective light penetration (inches)
61.7
32.4
32.2
Fluoride
2.4
2.4
< 5.0
1
Hardness
4,494
Iron, total
0.01
<0.3
<0.001
Lead, dissolved
<0.01
<0.05
Magnesium
967
1,294
Nitrogen
Total Kjeldahl
0.40
0.13
0.06
0.02
Total nitrate
0.05
0.02
0.03
Asmonia
0.01
0.03
0.04
Oxygen, dissolved
6.37
7.2
7.0
>4.0
pH (standard units)
8.02
6.5-8.5
8.1
Phosphorus, dissolved orthophosphate
1.89
1.22
1.07
0.073
Potassium, dissolved
272.6
387
Salinity (parts per thousand)
28.9
24.9
24.7
Sodium, dissolved
8,382
10,760
Solids, suspended
13.2
42.6
61.0
Sulfate (as SO4)
2,098
2,712
Sulfide
0.03
Turbidity (Jackson units)
4.7
5.9
4.6
50
Water temperature (°C)
24.0
22.4
24.1
Zinc
<0.01
<1.0
<0.05
Abbreviations:
^mhos/cm - micromhos per centimeter.
SO4 ¦ sulfate.
"Average values from four Hillsborough County Environmental Protection Commission sampling stations
(Nos. 9, 73, 80, 81) in Hillsborough Bay near the Big Bend Station.
^Values in milligrams per liter unless otherwise indicated.
cHillsborough County Environmental Protection Commission (1973).
^Hillsborough County Environmental Protection Commission (1979).
Hillsborough County Environmental Protection Commission (1980).
^Applicable to most of Hillsborough Bay.
SMartin (1970).
''After reasonable mixing of discharge in receiving water.
-------
Table 1-11. Intake cooling-water quality at Big Bend Station®
Parameter
Minimum
Average
Maximum
pHb»0»d
7.3
8.5
Alkalinity, as C8C0315
102
154.2
300
Total solids^
23,550
25,199
26,580
Total suspended solids^
16.3
24.2
44.3
Nitrogen, nitrate as N*5
<0.05
0.05
0.05
Phosphorus, total as Pb
0.9
2.5
3.3
Sulfate, as S04c»c'
1850
1892
1965
Phosphatee
0.667
0.768
0.922
Organic phosphoruse
0.005
0.169
0.206
Ammoniae
0.04
0.07
0.08
Nitrite (N02)e
0.005
0.005
0.006
Nitrate (N03)e
0.005
0.023
0.046
Bromide6
0.71
1.52
2.98
Chloride*1»°
8326
12,774
19,813
Fluoride^5 »c»d
1.2
2.0
5.3
Aluminum®
<0.10
0.22
0.38
Antimony0
<0.2
0.5
0.8
Arsenic0
0.124
0.204
0.293
Beryllium0
<0.005
0.012
0.019
Cadmiume
0.001
0.001
0.001
Calcium0
116
276
330
Chromiume
0.006
0.022
0.045
Coppere
0.004
0.008
0.013
Irone
0.01
0.05
0.08
Leade
0.01
0.01
0.01
Magnesium1*'0
122
407
905
Manganesee
0.01
0.02
0.04
Mercurye
0.0001
0.0001
0.0002
Nickele
0.004
0.005
0.01
Selenium0
0.129
0.281
0.565
Potassium^'0
204
278
301
Sodium'3 »°
4550
7150
7600
Thallium0
<0.1
0.15
0.2
Oil and greasee
<1.0
1.5
1.9
Zince
0.007
0.008
0.011
Abbreviations:
CaC03 ¦ calcium carbonate.
N ¦ nitrogen.
P ¦ phosphorus.
SO4 ¦ sulfate.
aAll except pH data in milligrams per liter.
^Water-quality data for period April 29, 1973, through May 5, 1973,
Stone & Webster Engineering Corporation.
cWater-quality data for period October 15, 1979, through December 3,
1979, Tampa Electric Company Central Testing Laboratory.
dWater-quality data for June 26, 1979, Thorton Laboratories, Inc.
e316 Demonstration - BB4, Fine Mesh Screen Study Report, Tampa
Electric Company, November 1980, Station 1. Water-quality data
from six samples collected during period July-September 1980.
1-75
-------
Table 1-12. Water quality of site ground water and
suggested EPA standards3
Surficial aquifer at
site, March 1976^ Floridan
West
East
South
North
aquiferc
EPA
Parameter
well
well
well
well
1953
1974
standard
Phosphate, total
4.13
3.15
3.6
3.43
Silica
47.9
45.4
14.8
44.2
21
28
Calcium
692
155
176
1116
170
170
Magnes ium
173
51
53
384
65
52
Sodium
10,000
18
17
300
50
Potassium
1.9
0.5
1.6
1.4
3.1
Iron, total
1.46
0.64
0.66
0.81
0.28
0.10
Iron, dissolved
0.2
0.14
0.40
0.36
Nickel
0.0
0.0
0.0
0.0
Copper
0.01
0.01
0.01
0.01
1.0
Cadmiume
0.01
0.1
<0.01
0.01
Chromium
6.6
9.9
5.0
7.9
0.05
Leade
<0.05
<0.05
<0.05
0.05
Mercurye
<0.002
<0.002
<0.002
Seleniume
<0.5
<0.5
<0.5
0.01
Zinc
0.45
0.25
0.17
0.68
6.0
Manganese
0.12
0.18
0.18
0.24
0.05
V anadiume
<1
<1
<1
Sulfate
93.2
102.8
82.7
180.7
510
450
250
Chloride
2570
35
59
3317
88
100
250
Bicarbonate
172
173
Nitrogen
0.56
0.89
0.22
0.78
Nitrates
2.6
4.6
2.2
3.75
45
Arsenic®
0.28
0.05
0.06
Bromine
8.6
0.1
0
12.5
Phosphorus
0.04
0.22
0.2
0.08
0.4
0.6
Biological
oxygen demand
0
0
0
0
Total dissolved
solids
3641
4789
627
4329
1080
1000
500
Total suspended
solids
50
35
14
59
pH
7.00
6.96
8.35
6.4
7.3
7.3
Oil and grease
0
0
0
0
Turbidity (Ftu)
28
24
32
40
Abbreviations:
EPA ¦ U.S. Environmental Protection Agency.
Ftu ¦ Formazin turbidity units.
aAll data in parts per million unless otherwise indicated.
^Environmental Associates, Inc., analyses dated March 10, 1976.
cDuerr (1979).
^EPA standards for drinking water, primary and secondary.
elnterscience Associates, Inc., analyses dated December 15, 1975.
1-76
-------
Table 1-13. Summary of water-quality data for the Floridan aquifer
Parameter
Number of
wells
Maximum
Minimum
Median
Chloride, mgfa
90
3300
1
20
Sulfate, mg/{
87
990
0
235
Hardness (Ca, Mg), mg/{
52
2100
150
450
Specific conductance, /imhos
87
10,900
220
840
Total dissolved solids,® mgfa
87
8500
190
605
Abbreviations:
mg/f = milligrams per liter.
Ca = calcium.
Mg = magnesium.
/imhos = micromhos.
^otal dissolved solids as a function of conductivity.
1-77
-------
Table 1—14. Comparison of temperatures of the effluent from Unit 4 at the outfall
with seasonal ambient water temperatures for the once—through cooling alternative
Ambient water temperature8 (°F) Discharge-water temperature (°F)
Season/month Maximum Minimum Average Maximum Minimum Average
Winter
January
February
Summer
March
April
May
June
July
August
September
October
Winter
November
December
66 54 59.6
63 50 57.9
75 58 66.4
85 67 76.8
85 73 80.0
89 81 85.6
94 82 87.2
90 79 86.1
88 82 85.4
84 71 76.9
79 67 73.4
77 62 68.7
83 71 76.6
80 67 74.9
82 75 83.4
102 84 93.8
102 90 97.0
106 98 102.6
111 99 104.2
107 96 103.1
105 99 102.4
101 88 93.9
96 84 90.4
94 79 85.7
aIntake cooling-water data for 1978.
-------
Table 1-15. Continuous-discharge stream water quality® (Sheet 1 of 2)
Intake
cooling-water
Florida
concentration
D
City water
Boiler
Bottom-ash
FGD system
Combined
Class III
Parameter
Average
Minimis
Maximum
concentration0
blowdown
blowdown'*
blowdowne
effluents^
WQ standard
Plow (gpsi)
241,000
30
80
70 (max.)
241,180
Alkalinity
154.2
102
300
168
Total solid*
25,199
23,550
26,580
500
10
500 (min.)
91,300
Total suspended solids
24.2
16.3
44.3
20
4
30
30
Nitrate nitrogen
0.05
<0.05
0.05
<0.05
<0.05
<0.05
Phosphorus
2.5
0.90
3.3
<0.1
<0.01
<0.10
Sulfate
1892
1850
1965
44
44
55,700
1980
Phosphate
0.768
0.667
0.922
Organic phosphorus
0.169
0.005
0.206
0.0018
Ammonia
0.07
0.04
0.08
2
Nitrite
0.005
0.005
0.006
Nitrate
0.023
0.005
0.046
Bromide
1.52
0.071
2.98
0.48
0.48
0.48
2.9781
Bromine, 0.1;
bromates, 100
Chlorine
<0.2 FAC
<0.01 TRC
Chloride
12,774
8,326
19,813
23
23
26,200
19,806
Maximum 10% above
background
Fluoride
2.0
1.2
5.3
0.5
0.50
0.50
5.2964
5.0
Aluminum
0.22
<0.1
0.38
1.5
Antimony
0.50
<0.2
0.80
(h)
0.2
Arsenic
0.204
0.124
0.293
0.193
0.02
0.250
0.2929
0.05
Beryllium
0.012
<0.005
0.019
<0.005
-------
Table 1-15. Continuous-discharge stream water quality® (Sheet 2 of 2)
Abbreviation*:
FCD " flue-gas desulfurisation,
HQ - water quality.
gpm " gallons per minute.
FAC ~ Florida Administrative Code.
TR.C » total residual chlorine.
"All concentrations in milligrams per liter unless otherwise indicated.
''Data were obtained fran the following five sources, as noted in the U.S. Environmental Protection Agency NPDES permit application:
1. Hater-quality data for the period April 29, 1973, through Hay 5, 1973, Stone & Webster Engineering Corporation.
2. Water-quality data for October 15, 1979, through December 3, 1979, Tampa Electric Company Central Testing Laboratory.
3. Water-quality data for June 26, 1979, Thorton Laboratories, Inc.
4. TECO <1980d).
Analytical results for city water taken at Sample Point 13 on April 29, 1973 ( 24-hour composite values).
^Values reflect effluent concentrations from bottom-ash pond at plant burning southern Illinois coal. Treatability of Ash Settling Pond
Effluents, Utility Water Act Group (1979).
^Values reflect estimated concentrations after treatment. Values estimated for "combined effluent" concentrations are based on before-
treatment concentrations for conservative estimates.
^Combined effluents were calculated from maximum intake-water concentrations.
^Standards for elemental phosphorus.
j^Less than minimum quantifiable concentration from Treatability of Ash Settling Pond Effluenta, Utility Water Act Group (1979)-
LThe chromium standard is 1.0 milligram per liter total and 0.05 milligram per liter after reasonable mixing of discharge in
.receiving water.
^Maximum value. Estimated values are 0.04 milligram per liter for copper and 0.001 milligram per liter for iron.
-------
Table 1-16. Big Bend Unit 4 discharge-water quality following treatment
to meet State and Federal effluent limitations8
Detectable effluent
Bottom- water quality
Boiler FGD ash Intake circulating at combined Florida water-
Parameter blowdown^ blowdown blowdown water (maximum)0 discharge quality standard
Arsenic
0.193
0.250
0.02
0.232
0.232
0.05
Cadmium
<0.005
0.01
<0.005
<0.055
0.055
0.005
Chromium
0.065
0.03
0.01
0.075
0.075
0.05
Copper
1
0.06
0.003
0.098
0.098
0.015
Iron
1
0.05
0.71
1.014
1.014
0.3
Lead
<0.1
0.05
0.005
0.1
0.1
0.05
Mercury
0.007
<0.0002
<0.0002
0.0540
0.0540
0.0001
Nickel
0.096
0.03
0.02
0.180
0.180
0.1
Selenium
0.032
0.009
<0.004
0.112
0.112
0.025
Zinc
0.05
0.24
0.05
0.302
0.302
1.0
aAll data in milligrams per liter.
kjlo treatment required to meet effluent standards.
cFrom 1981 data.
-------
Table 1-17. Big Bend Unit 4 discharge-water quality following treatment to meet State and
Federal effluent limitations and reverse—osmosis treatment of the blowdown streams®
Parameter
Combined
blowdowtv streams
after heavy-
metal treatment
Intake
circulating
water
(maximum)'*
Combined
detectable
water quality
at discharge
(heavy-metal
removal)
Combined
detectable
water quality
at discharge
(no heavy-
metal removal)
Florida
water-
quality
standard
Arsenic
0.05
0.232
0.232
0.232
0.05
Cadmium
0.005
0.055
0.055
0.055
0.005
Chromium
0.045
0.075
0.075
0.075
0.05
Copper
0.015
0.098
0.098
0.098
0.015
Iron
0.3
1.014
1.014
1.014
0.3
Lead
0.038
0.1
0.1
0.1
0.05
Mercury
0.0001
0.054
0.054
0.054
0.0001
Nickel
0.037
0.180
0.180
0.180
0.1
Selenium
0.011
0.112
0.112
0.112
0.025
Zinc
0.012
0.302
0.302
0.302
1.0
aAll data in milligrams per liter.
^From 1981 data.
-------
Table 1-18. Checklist of special status species (Sheet 1 of 2)
Species
Expected
at site
Local
activity
Federal State
status* status*'*1
Local habitat
Primary
impacts6
Shellfish
Mangrove crab
Atlantic geoduck
Fish
Atlantic sturgeon
Rivulus
Opossum pipefish
Mountain mullet
Terrestrial invertebrates
Stock Island tree snail
Bahama swallowtail
butterfly
Schaus swallowtail
butterfly
Florida tree snail
Atala butterfly
Gopher tortoise
copris beetle
Peninsular gopher
tortoise dung beetle
Gopher tortoise
aphodium beetle
Southwest Florida
wingless burrowing
beetle
Abotis purse-web spider
Scarab beetles
<3 species)
Amphibians/reptiles
Florida crawfish frog
River cooter
Gopher tortoise
American alligator
Eastern indigo snake
Short-tailed snake
Atlantic loggerhead
Atlantic green
Atlantic leatherback
Atlantic ridley
Birds
Hood stork
Peregrine falcon
Cuban snowy plover
Yes
Resident
Unknown
Possible Resident
Possible Resident
Possible Resident
Possible Resident
No ~
Ho —
No
Ho
Unknown
Possible
Possible
Possible
Possible
Unknown
(d)
(d)
Possible
Possible Unknown
Possible Resident
Ho
Possible Resident
Possible
Yes
No
Possible
Possible
No
Possible
Yes
Possible
No
Resident
Resident
Rare visitor
Rare visitor
Rare visitor
Peeding
Rare visitor
T
R
T
T
R
R
T
T
T
T
T
T
T
SC
u
SC/T
SC/T
SC/T
SC
SC
T/B
T
E
E/R
E
E
E
E
Mangroves
Subtidal
Anadroaous
Mangroves; salt marsh
Estuarine Unknown
Brackish/freshwater Unknown
Catadroaous Unknown
Ho long-term
Siltation
Water pollution
Unknown
(d)
(d)
Meaic woods
Unknown
Prairie; dry pine
flatwoods
Prairie; dry pine
flatwoods
Wetlands
Myrtle/saltbush, pines
Estuarine
Estuarine
Estuarine
Freahwater wetlands
Mangroves
Unkncpm
Loss of habitat
Loss of habitat
Loss of habitat
No long-term
Unknown
Loss of habitat
Loss of habitat
No long-term
Loss of habitat
Loss of habitat
Ho long-term
Wo long-term
No long-term
Collision; no long-term
Collision; no long-term
Red-cockaded
No
—
e
T/E
—
—
woodpecker
Eastern brown pelican
Yes
Feeding
e
T
Mangroves
Collision; no long-term
Southern bald eagle
Possible
Feeding
e
T
Near water
Collision; electrocution
Southeast American
No
—
T
—
—
kestrel
Audubon1s caracara
Possible
Visitor
T
Grasslands
Loss of habitat
Florida sandhill crane
No
—
T
—
—
American oystercatcher
Ye*
Possible resident
SC/T
Beaches; mudflats
Ho long-term
Leaat tern
Yes
Possible resident
T
Beaches
Ho long-term
Florida scrub jay
Ho
—
T
—
—
Reddish egret
Yes
Feeding
SC/R
Saltwater wetlands
No long-term
Roseate spoonbill
Yes
Feeding
SC/R
Mangroves
Ho long-term
Little blue heron
Yes
Feeding
SC
Wetlands
No long-term
Snowy egret
Yes
Feeding
SC
Wetlands
Ho long-term
Rothschild's magni-
Possible
Visitor
T
Mangroves
Collision
ficent frigatebird
Osprey
Yes
Feeding
T
Aquatic
Collision; electrocution
White-tailed kite
Ho
—
R
Grasslends; marshes
Collision; electrocution
Short-tailed hawk
Possible
Visitor
R
Coastal swamps
Collision; electrocution
Mangrove cuekoo
Possible
Resident
R
Mangroves
No long-term
Black-whiekered vireo
Possible
Resident
R
Mangroves
Ho long-term
Florida great white
Possible
Feeding
SC
Coastal
No long-term
heron
Great egret
Yes
Resident
SC
Coastal; wetlands
No long-term
Black-crowned night
Possible
Resident
SC
Swamps; tidal marshes
No long-term
heron
Yellow-crowned night
Yes
Resident
SC
Swamps; tidal marshes
No long-term
Note: See footnotes at end of table.
1-83
-------
Table 1-18. Checklist of special status species (Sheet 2 of 2)
Species
Expected
at site
Local Federal
activity status*
State
status1*^
Local habitat
Primary
impacts0
ds (continued)
Eastern least bittern
Yes
Resident
SC
Mangroves
No long-term
Glossy ibis
Yes
Resident
SC
Mangroves; marshes
No long-term
White ibis
Yes
Resident
SC
Coastal
No long*term
Cooper's hawk
Possible
Feeding
SC
Woodlands
No long*term
Piping plover
Possible
Feeding
SC
Beaches
No long-term
American avocet
Possible
Migrant
SC
Wetlands
No long-term
Royal tern
Yes
Resident
SC
Saltwater beaches
No long-term
Sandwich tern
Possible
Feeding
SC
Beaches
No long-term
Caspian tern
Yes
Resident
SC
Beaches
No long-term
Black skimmer
Yes
Resident
SC
Mangroves; beaches
No long-term
Southern hairy
Possible
Resident
SC
Woodlands
No long-term
woodpecker
prairie warbler
Yes
Resident
SC
Various
No long-term
Louisiana heron
Yes
Feeding
SC
Wetlands
No long-term
Liapkin
Possible
Possible resident
SC
Freshwater wetlands
No long-term
Florida burrowing owl
Possible
Visitor
SC
Prairies; pasture
Loss of habitat
Marian* marsh wren
Mo
—
SC
—
Lose of habitat
¦male
Sherman*s fox squirrel
No
—
SC/T
—
—
Florida mouse
Ho
—¦
T
—
—
Black bear
Mo
R
—
Florida panther
No
— e
E
—
—
Manatee
Ye«
Wintering; feeding e
E/T
Saltwater, wetlands
Use of warmed discharge
water; mortality from
powercraft, poaching;
habitat loss
River otter
No
u
—
—
Bobcat
No
u
—
—
Big brown bat
No
—
R
—
—
Rafinesque'e bat
No
R
—
Florida weasel
Possible
Resident
R
Variety
Loss of habitat
Round-tailed muekrat
Possible
Resident
SC
Freshwater wetlands
No long-term
•Keyt
E - endangered,
T • threatened.
8C ¦ special status.
R ¦ rare.
1) * under review.
e - endangered (45 FR 99, 33768-33781).
t - threatened (43 FR 99, 33768-33781).
u - under review (45 IS. 99, 33768-33781).
^Species status based on designation by either the Florida Game and Fresh Water Fish Comission (1979) or the Florida
Committee on Hare and Endangered Plants and Animals (Tables 1-61 through 2-63; 1976).
^Possible secondary impacts are a decrease in environmental quality and reduction of habitat.
^Associated with the gopher tortoise.
1-84
-------
IW N
Tampa (1960-1964) Tampa (1965-1969)
Tampa (1971-1975) MacDill (1965-1969)
1 - Wind direction frequency (%)
Mean wind speed (mph)
Figure 1-7. Annual wind roses for Tampa and MacDill.
1-85
-------
Power station boundaries of Tampa Electric Company, 1973.
"Big Bend Lands" engineering line drawing dated November 8, 1973.
1 Ruderal community 7
2 Power-line right-of-way 8
3 Successionally advanced ruderal community 9
3A Successionally advanced ruderal community io
4 Freshwater wetlands 11
5 Pine flatwoods 12
6 Mangrove community
Mangrove-pine flatwoods transition area
Pine flatwoods g
Pasture
Pasture pond
Artificial barren land
Ruderal community
ft
500 1000 Feet
Figure 1-8. Vegetation cover types of Big Bend Station.
1-86
-------
fOl Active agricultural area
Figure 1-9. Annual salt-deposition rate (lb/(acre-yr)) for a mechanical-draft
cooling tower at Big Bend Station.
-------
0 1Mile
Figure 1-10. Isothermal contour map for three generating units operating at 100 percent load
with no dilution pumps. Big Bend Station.
1-88
-------
Figure 1-11. Isothermal contour map for four Big Bend units operating
at 100 percent load with no dilution pumps.
1-89
-------
1.4 OTHER NEPA CONSIDERATIONS
1.4.1 UNAVOIDABLE ADVERSE IMPACTS
The proposed action will result in certain adverse environmental impacts,
despite the emphasis on state-of-the-art impact control technology in all
project particulars. 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. In the Big Bend 4
project, every effort will be made to ensure the most environmentally favor-
able tradeoffs between construction and operation of the generating unit
and the use of air, land, and water resources.
Descriptions of the unavoidable impacts of the new generating unit are pre-
sented in the following sections.
1.4.1.1 Atmospheric Resources
There will be an increase in pollutants released to the atmosphere as a
result of the proposed station. The emissions of sulfur dioxide, nitrogen
dioxide, and particulates from the proposed station will not result in any
violation of Federal or State ambient air quality standards. Air emissions
will use up portions of available prevention of significant air quality
deterioration Class II increments at points close to the facility. This
will not preclude future industrial development in the site region.
Emissions of sulfur dioxide and nitrogen oxides 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 deposition in a particular area remains
speculative. The most highly publicized relationship is that between emis-
sions from the industrial Midwestern and the Eastern United States and "acid
rain'1 in the Northeastern United States and Canada.
The operation of the proposed facility will not have any significant impact
on the levels of atmospheric ozone.
1.4.1.2 Land Resources
There will be a loss of approximately 66 acres of pastureland and 31 acres
of agricultural land owing to the development of the gypsum storage and
disposal area. This use of the land will result in a loss or displacement
of the wildlife now using this habitat. Approximately 121 acres of addi-
tional land will be preempted by the ash disposal system, resulting in a
loss of this wildlife habitat as well.
Neither loss is considered significantly adverse because these habitats have
been recently disturbed and are not unique to the Big Bend site or to the
surrounding areas. Moreover, they are among the least biologically important
wildlife habitats at the site.
1-90
-------
1.4.1.3 Water
Construction of the Unit 4 discharge structure will require the removal of
approximately 690 cubic yards of sand and silt from the bottom of the dis-
charge canal. This will result in the direct loss of many benthic inverte-
brate organisms.
Prototype studies at the site have confirmed that the fine-mesh screening
of intake structures is a feasible technology that will minimize entrainment
effects. They have also shown that the installation of fine-mesh screens
on the intake structures of Big Bend Units 3 and 4 will result in entrainment
effects approximately equal to the current impacts associated with the opera-
tion of Units 1, 2, and 3 using conventional intake technology. These impacts
are not expected to be significant.
1.4.1.4 Sensitive Areas
The indigo snake is the only rare, endangered, or threatened species on which
the construction and operation of Unit 4 could have a direct adverse impact.
This species was reported on the site in 1974 and could occur in habitat types
that will be disturbed by the Big Bend 4 project. It cannot be determined
from available information, however, whether the species presently inhabits
the site and thus whether in fact it will be adversely affected.
A small 1-acre pond and marsh area will be destroyed by the construction^
of the gypsum storage and disposal area. This loss is not deemed signifi-
cant, however, because of the small size of the area and the presence of
other larger wetland areas in the region.
The existing drainage patterns on the site will be modified to accommodate
disposal areas for gypsum and ash. The most significant of these modifica-
tions will be the relocation of Jackson Branch.
1.4.2 RELATIONSHIP OF SHORT-TERM USES OF MAN'S ENVIRONMENT AND MAINTENANCE
AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
During the proposed 30-year life of Unit 4, the air, water, and land resources
of the site will be committed to the production of electric power. There
will be no commitment of new resources beyond the site, since the existing
transmission right-of-way will be used for new power lines and all solid
wastes will be disposed of at the site or sold for commercial use.
The production of electricity during the operating life of the station will
contribute to tourism and other industries within the TECO service area and
within those of other utilities purchasing power from Unit 4. This electric
power will accommodate the projected increase in the population of the region
and will contribute to the health and safety of the general populace.
1.4.3 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES
The proposed plant will consume an estimated 28.5 million tons of coal
during its 30-year life. The consumption of fuel oil for startup and flame
stabilization is expected to be 10,143 barrels over the life of the station.
1-91
-------
The FGD system will use an estimated 3.4 million tons of limestone during
plant life. Most of this resource will be irretrievably committed; some,
however, will be recovered as gypsum, which could be sold for wallboard
manufacture.
Materials like concrete cannot be recycled and thus will be irretrievably
committed to the construction of the station. Other materials, such as
steel and aluminum, may be reclaimed if it is economically feasible.
Approximately 218 acres of agricultural and grazing land will be irretriev-
ably committed to the storage of gypsum (97 acres) as well as bottom and fly
ash (121 acres). A small 1-acre marsh will be likewise committed.
1.4.4 CONFLICTS BETWEEN THE PROPOSED ACTION AND THE OBJECTIVES OF FEDERAL,
REGIONAL, STATE, AND LOCAL PLANS
There are no known conflicts between the proposed action and any Federal,
regional, State, or local plans for the Big Bend area.
1-92
-------
Chapter 2
ERRATA
The following corrections and/or additions should be made to the Draft
Environmental Impact Statement.
Page
1-1
1-2
1-3
Paragraph
5
1-3
2-3
2-23
2-24
2-26
2-48
Figure 2-4
Figure 2-5
Table 2-5
Line(s)
4
7 & 8
5 & 6
Correction
Approximate number of cus-
tomers should be 316,000.
Insert "(See Figure 1-2)"
after "(System Planning
Committee, 1979)."
Delete sentence beginning:
"Therefore, any further...."
and replace with the follow-
ing, "Furthermore, delay in
constructing Big Bend Unit 4
would potentially jeopardize
future service to customers
(Appendix G)."
The sentence should begin:
"Alternatives to the need
for this project..."
The sentence should read:
"Further, all efforts to
obtain capacity from other
utilities have been deter-
mined not to be cost- or
time-effective on the basis
of the economics considered."
See Figure 2-4R. The loca-
tion of NPDES Serial No. 001
has been corrected.
See Figure 2-5R, corrected
water balance diagram.
The sentence should begin,
"As a result of EPA con-
cerns ..."
For alternatives 8 and 9,
entrainment impacts should
read "None."
2-1
-------
Page Paragraph Line(s)
2-61 1 all
3-4 4 8
3-19 Table 3-11 footnote £
3-25 Table 3-18
3-61 3 4
3-63 4 2
3-63 4 3
3-91 Table 3-26
3-163 2 8
3-164 5 2
3-164 6 5/6
F-ll all all
Correction
See page 1-22 of FEIS (Sec-
tion 1.2.7) for correct
language
"900 tons per year" should
read: "1200 tons per year"
"46,920,000 Btu/hr" should
read: "4,692 MMBtu/hr"
Second line of title should
read, "summary of ORFAD
modeling results3."
"(Table 3-33)" should read
"(Table 3-38)."
"Table 3-39" should read
"Table 3-40."
"Table 3-40" should read
"Table 3-41."
Value for zinc in column 5
should be 0.05.
Table 3-53 was omitted from
DEIS. A copy is included
herein.
"Table 3-15" should read
"Table 3-7."
"Figure 3-29" should read
"Figure 3-21."
Replace existing page F-ll
with corrected page F-11R
2-2
-------
ro
N>
U>
5*
Figure 2-4R. Plot plan, Big Bend Station.
-------
ro
\
N>
Soot
Venr blowing
losses losses
To bay
Evapo tion
Bay water
or alternative
water source
Closed-cycle cooling alternative
Alternative
water source
Alternative
water source
(007>
To intake
and discharge
canals
(012 & 013}
Unit 4
condenser
To bay {008")
Once-through
cooling alternative
Bottom-ash
blowdown
to bay
Notts: Sea Table 2-4 for key.
Numbers in parentheses refer to NPDES Serial Numbers.
Figure 2-5R. Plant water balance for Big Bend Station.
-------
Table 3-53. Checklist of special status species (Sheet 1 of 2)
Expected
Local
Federal
State
Primary
Species
at site
activity
status8
status*:
Local habitat
impacts0
Shellfish
Mangrove crab
Yes
Resident
T
Mangroves
No long-term
Atlantic geoduck
F i sh
Unknown
—
R
Subtidal
Siltation
Atlantic sturgeon
Possible
Resident
T
Anadromous
Water pollution
Mangroves; salt marsh
Rivulus
Possible
Resident
T
Estuarine
Unknown
Opossum pipefish
Possible
Resident
R
Brackish/freshwater
Unknown
Mountain mullet
Possible
Resident
R
Catadromous
Unknown
Terrestrial invertebrates
Stock Island tree snail
No
—
t
T
—
—
Bahama swallowtail
butterfly
No
—
t
T
—
—
Schaus swallowtail
butterfly
No
—
t
T
—
—
Florida tree snail
No
—
u
—
—
—
Atala butterfly
Unknown
Unknown
u
—
Unknown
Unknown
Gopher tortoise
Pos8 ible
T
copris beetle
Peninsular gopher
Possible
(d)
T
Loss of habitat
tortoise dung beetle
Gopher tortoise
Poss ible
(d)
T
(d)
Loss of habitat
aphodium beetle
Southwest Florida
Possible
—
T
—
Loss of habitat
wingless burrowing
beetle
Abotis purse-web spider
Poss ible
SC
Mesic woods
No long-term
Scarab beetles
Possible
Unknown
U
Unknown
Unknown
(3 species)
Amph ib ians/rept i1es
Florida crawfish frog
Possible
Resident
SC/T
Prairie; dry pine
Loss of habitat
flatwoods
River cooter
No
—
SC/T
—
—
Gopher tortoise
Possible
Resident
SC/T
Prairie; dry pine
Loss of habitat
flatwoods
American alligator
Possible
Resident
t
SC
Wetlands
No long-term
Eastern indigo snake
Yes
Resident
t
SC
Myrtle/saltbush, pines
Loss of habitat
Short-tailed snake
No
—
T/E
—
Loss of habitat
Atlantic loggerhead
Possible
Rare visitor
t
T
Estuarine
No long-term
Atlantic green
Possible
Rare visitor
e
E
Estuarine
No long-term
Atlantic leatherback
No
—
e
E/R
—
—
Atlantic ridley
Possible
Rare visitor
e
E
Estuarine
No long-term
Birds
Wood stork
Yes
Feeding
E
Freshwater wetlands
Collision; no long-term
Peregrine falcon
Possible
Rare visitor
e
E
Mangroves
Collision; no long-term
Cuban snowy plover
No
—
E
—
Red-cockaded
No
—
e
T/E
—
—
woodpecker
Collision; no long-term
Eastern brown pelican
Yes
Feeding
e
T
Mangroves
Southern bald eagle
Possible
Feeding
e
T
Near water
Collision; electrocution
Southeast American
No
—
T
—
—-
kestrel
Audubon's caracara
Possible
Visitor
T
Grasslands
Loss of habitat
Florida sandhill crane
No
~
r
—
—
American oystercatcher
Yes
Possible resident
SC/T
Beaches; mudflats
No long-term
Least tern
Yes
Possible resident
T
Beaches
No long-term
Florida scrub jay
No
—
T
—
Reddish, egret
Yes
Feeding
SC/R
Saltwater wetlands
No long-term
Roseate spoonbill
Yes
Feeding
SC/R
Mangroves
No long-term
Little blue heron
Yes
Feeding
SC
Wetlands
No long-term
Snowy egret
Yes
Feeding
SC
Wetlands
No long-term
Rothschild's magni-
Possible
Vis itor
T
Mangroves
Collision
ficant frigatebird
Collision; electrocution
Osprey
Yes
Feeding
T
Aquatic
White-tailed kite
No
—
R
Grasslands; marshes
Collision; electrocution
Short-tailed hawk
Possible
Visitor
R
Coastal swamps
Collision? electrocution
Mangrove cuckoo
Possible
Resident
R
Mangroves
No long-term
Black-whiskered vireo
Possible
Resident
R
Mangroves
No long-term
Florida great white
Possible
Feeding
SC
Coastal
No long-term
heron
Great egret
Yes
Resident
SC
Coastal; wetlands
No long-term
Black-crowned night
Possible
Resident
SC
Swamps; tidal marshes
No long-term
heron
Yellow-crowned night
Yes
Resident
SC
Swamps; tidal marshes
No long-term
heron
Note: See footnotes at end of table.
3-166a
-------
Table 3-53. Checklist of special status species (Sheet 2 of 2)
Expected
Local
Federal
State
Primary
Species
at site
activity
status®
status®*^
Local habitat
impactsc
"ds (continued)
Eastern least bittern
Yes
Resident
SC
Mangroves
No long-term
Glossy ibis
Yes
Resident
SC
Mangroves; marshes
No long-term
White ibis
Yes
Resident
SC
Coastal
No long-term
Cooper's hawk
Possible
Feeding
SC
Woodlands
No long-term
Piping plover
Possible
Feeding
sc
Beaches
No long-term
American avocet
Possible
Migrant
SC
Wetlands
No long-term
Royal tern
Yes
Resident
SC
Saltwater beaches
No long-term
Sandwich tern
Possible
Feeding
SC
Beaches
No long-term
Caspian tern
Yes
Resident
SC
Beaches
No long-term
Black skinner
Yes
Resident
SC
Mangroves; beaches
No long-term
Southern hairy
Possible
Resident
SC
Woodlands
No long-term
woodpecker
Prairie warbler
Yes
Resident
SC
Various
No long-term
Louisiana heron
Yes
Feeding
SC
Wetlands
No long-term
Limpkin
Possible
Possible resident
SC
Freshwater wetlands
No long-term
Florida burrowing owl
Possible
Visitor
SC
Prairies; pasture
Loss of habitat
Marians marsh wren
No
—
SC
—
Loss of habitat
una Is
Sherman's fox squirrel
No
—
SC/T
—
—
Florida mouse
No
—
T
—
—
Black bear
No
—
R
—
—
Florida panther
No
__
e
G
—
—
Manatee
Yes
Wintering; feeding
e
E/r
Saltwaterf wetlands
Use of warmed discharge
water; mortality from
powercraft, poachingj
habitat loss
River otter
No
—
u
—
—
Bobcat
No
—
u
—
Big brown bat
No
—
R
—
Rafinesque's bst
No
R
—
Florida weasel
Possible
Resident
R
Variety
Loss of habitat
Round-tailed muskrat
Possible
Resident
SC
Freshwater wetlands
No long-term
•Keys
E ¦ endangered.
T " threatened.
SC ¦ special status.
R ¦ rare.
U « under review.
e - endangered (45 FR 99, 33768-33781).
t - threatened (45 FR 99, 33768-33781).
u - under review (45 FR 99, 33768-33781).
^Species status based on designation by either the Florida Game and Fresh Water Fish Commission (1979) or the Florida
Comittee on Rare and Endangered Plants and Animals (Tables 1-61 through 2-65; 1976).
^Possible secondary impacts are a decrease in environmental quality and reduction of habitat.
dAs«oci«ted with the gopher tortoise*
3-166b
-------
Parameter
Location
Sample Type
Frequency
Flow, Cooling
Flow, Bottom Ash
Flow, Boiler Blow-
down
Flow, FGD Bleed
PH
Temperature
TSS
Chlorine, Total
Residual
Oil and Grease
Metals
Intake
Prior to CWS
Prior to CWS
Prior to CWS
CWS and prior to
CWS on FGD Bleed
Boiler & Bottom
Ash Blowdown
CWS Outfall
Bottom Ash Blow-
down, FGD Bleed,
& Boiler Blowdown
Outfall
Boiler Blowdown
Bottom Ash Blow-
down and FGD
bleed
Intake, Outfall
FGD Bleed Stream
Bottom Ash Blow-
down & Boiler
Blowdown Prior
to discharge
to CWS
Arsenic
Cadmium
Iron
Lead "
Mercury
Selenium
-7 • 11
Zinc
Copper
Chromium
Nickel
2. Biological Monitoring
a. Thermal Studies
Pump Log
Recorder
Daily Log
Recorder
Grab
Recorder
Grab
Multiple Grab
Grab
Two-Grab
composite, not
less than two
hours between
samples
Conti nuous
Conti nuous
Dai ly
Continuous
Two per Week
Conti nuous
Two per Week
Two per Month
Weekly
Two per Month
Two per Month
for the first
year, then monthly
thereafter
Sampling shall be done on a bi-monthly basis commencing one month
after certification and shall continue for a period of one year after
Unit 4 is on-line. Such sampling shall consist of a baseline survey and
an intensive survey. Sampling methodology shall be the same as that in
the 1979 aquatic biology studies. Deviations from that methodology
shall be approved by the DER.
All raw data shall be available upon request by DER. At the end of
the first year of post-operational study, the Department shall review all
of the data in the form of an annual report and shall determine if
*CWS - Cooling Water System
Revised 6/2/81
F-11R
-------
Chapter 3
MONITORING PROGRAMS
3.1 GROUNDWATER MONITORING PROGRAM
A groundwater monitoring program will be implemented one year prior to the
scheduled commercial operation date of Unit 4.
The groundwater monitoring well system is shown generally in attached Fig-
ure 3-1. The monitoring well system will consist of eleven new wells and
three existing wells. Ten of the new wells will be designed to monitor
groundwater quality in the top 40 feet of the surficial aquifer. One well
will be installed to a depth greater than 40 feet but less than 100 feet
to monitor vertical dispersion of groundwater contaminants. Surficial aqui-
fer wells will be designed, screened and constructed in a manner appropriate
for each well location. The exact placement of all the new wells will take
into consideration the part of the disposal areas to be used during the first
two years of operation. The specific well location and design information
(including depth, size, screen design and other features) will be submitted
to the U.S. Environmental Protection Agency (EPA), the Florida Department of
Environmental Regulation (DER) and the Southwest Florida Water Management
District (SWFWMD) for review and approval.
Water quality sampling and analyses will be performed monthly during the year
prior to commercial operation and for two years afterwards. Thereafter, anal-
yses will be performed quarterly. When a well is to be sampled, it will first
be pumped to obtain a representative sample from the surrounding aquifer.
Specific conductance will be monitored as this water is removed from the well.
Water will be pumped from the well until the conductivity reading stabilizes
or until two casing volumes are removed (whichever is greater). A sample will
then be obtained. Each sample will be analyzed according to EPA approved test
methods for conductance, pH, chloride, iron, cadmium, zinc, copper, sulfate,
silver, nickel, selenium, chromium, arsenic, beryllium, mercury, lead, gross
alpha and barium.
Results will be submitted quarterly with the Discharge Monitoring Reports.
Should the levels of any parameter show a consistent increase above background
levels, EPA and DER will be consulted to determine a course of action accept-
able to TECO, EPA, and DER. Based upon the observed trends in the data, an
estimate will be made of the point in time when the groundwater quality stand-
ards may potentially be exceeded at the boundary of the site. Corrective meas-
ure will be initiated within this period of time. Measures to be taken in-
clude sealing, relocating or altering operations of the wastewater treatment
ponds, spray irrigation field, FGD by-product area, bottom ash area, fly ash
area or coal storage pile.
In the event that changes in the monitoring program become necessary or that
no significant contamination is occurring due to commercial operation of
Unit 4, after consultation with and approval by EPA and DER the program will
be modified or eliminated.
3-1
-------
Big Bend Unit A
Groundwater Monitoring
Program Plan
Figure 3-1.
Piezometric surface map of the surficial aquifer, March 1973, Big Bend Station, Tampa Electric Company.
-------
3.2 CONSTRUCTION EROSION AND SEDIMENTATION CONTROL PROGRAM PLAN
This plan describes the program to be used to control rainfall-related soil
erosion and resulting sedimentation in area waters associated with the con-
struction of Big Bend Unit 4.
As the construction area of the unit building borders the intake and discharge
channels, measures will be taken to ensure that rainfall runoff from this
area does not flow into these channels. These measures include (1) flow
direction control through grading and modification of the existing drainage
system and (2) placement of straw bales. The existing storm water drainage
system in the unit building area is a system of lateral swales, connecting
and draining to existing ditches which drain to the channels. This system
will be modified by a new drainage system, consisting of trapezoidal swales,
catch basins and corrugated metal drainage pipe, which will convey the run-
off to the existing concrete flume. The unit building site will be graded
to drain into the newly installed storm drainage system as shown in the
attached drawing. All drainage originating from the unit building site
will be captured by the new storm water system. In addition, straw bales
will be placed along the road ditches paralleling the intake and discharge
channels and other strategic locations to assure water quality in the adja-
cent channels is not degraded due to runoff. Whereas all runoff is designed
to be contained by the proposed system, the straw bales will provide addi-
tional protection for the water quality of the channels.
During construction of the bottom ash, flyash and FGD by-product storage/
disposal facilities, rainfall runoff will be controlled by the use of meas-
ures such as straw bales, berms, barriers and vegetative planting. During
construction, disturbance of the existing ground cover and exposure of un-
protected, disturbed areas will be kept to a minimum. In some cases, such as
FGD by-product storage areas II, III, and IV, facilities will be developed
incrementally; vegetative cover will only be disturbed as the need for these
areas are realized and they are subsequently developed. During construction,
straw bales will be placed along the relocated Jackson Branch at the northern
boundary of the construction area, the east side of the road ditch along the
west boundary of the construction area, and other locations downstream of
disturbed land areas. These straw bales will remove silt and sediment from
the sheet runoff prior to entering Jackson Branch, the discharge channels
or any other tributaries.
Reports will be prepared to provide analyses of any problems associated with
the control measures and plans to reduce or eliminate such problems. These
reports will be submitted quarterly during the first year of construction
and semiannually thereafter, and shall be transmitted with the Discharge
Monitoring Reports for the Big Bend Station NPDES permit.
3-3
-------
3.3 FINE MESH SCREEN ORGANISM RETURN SYSTEM
As described in the Draft EIS, Tampa Electric Company proposed to utilize
fine mesh screens on the proposed Big Bend Unit 4 intake structure and the
existing Unit 3 intake structure. Aquatic studies conducted prior to the
Draft EIS indicated an unacceptably high level of entrainment associated
with the Big Bend Station (see Draft EIS, Appendices C and D). The fine
mesh screen system, as a result, was designed to limit the entrainment of
planktonic organisms for the entire proposed Big Bend Station (Units 1-4)
to acceptable levels.
Organisms removed from the fine mesh screens would be returned via a sluicing
mechanism to the Tampa Bay system. The canal immediately north of the Big
Bend Station was originally proposed as the location to receive the screened
organisms. However, dye studies conducted since publishing the Draft EIS
have indicated that organisms returned to this location would have a high
potential for being re-entrained into the Big Bend Station intake. Conse-
quently, alternatives to this location have been investigated. A summary of
the conclusions of the investigation are presented in this section.
3.3.1 ENGINEERING EVALUATION OF ALTERNATIVE LOCATIONS
Tampa Electric Company evaluated the engineering potential for several alter-
native organism return locations. The locations are shown in Figure 3-2 and
the evaluation results are described below and outlined in Table 3-1.
Location I
Location I is the eastern end of the canal north of the Big Bend Station in-
take canal. The routing distance from the intake structure is approximately
1,800 feet and is relatively obstruction free. The distance, topography, and
relatively few obstructions allow for a gravity flow system to this location.
Cost of construction for this location is $500,000. This is essentially the
alternative described in the Draft EIS.
Location II
Location II is the north Apollo Beach embayment, just south of the plant dis-
charge canal. The canal is separated from the embayment by a sheetpile wall.
Routing to this location offers two potentials. Route A would be a nearly
direct line from the plant intake to the release point parallel and adjacent
to the east end of the main plant structure. Due to its proximity to the
plant, the route would traverse congested areas. This route may allow for
a gravity flow system. Route B would head east from the intake structure
then south on the east side of the Unit 4 FGD system and then west to the
release point. The length of this route, 4,900 feet, may dictate the need
for pumping. The cost of this route is approximately $1,300,000. The
cost for Route A is $500,000, assuming pumping is not required.
3-4
-------
Location III
Location III is just west of the breakwater off Fish Hook Key. This route
would be 8,400 feet long and would require pumping. The estimated cost for
this option is $2,500,000.
Location IV
Location IV is the east end of the canal north of the Agrico facility. The
routing distance to this location is 6,700 feet. This option would require
pumping and would cost $1,900,000.
Based on economics, construction, and maintenance considerations, Location I
would appear to be the most favored site for the organism return system
release point. Location II would appear to be the second most favorable
release point. Locations III and IV would appear to be the least favorable.
The results of dye studies have indicated a high re-entrainment potential for
Location I. Location II, in the Apollo Beach northern embayment south of the
Big Bend Station, is considered to have a low re-entrainment potential. Con-
sequently, Location II may be an environmentally acceptable release point.
3.3.2 DESCRIPTION OF APOLLO BEACH NORTHERN EMBAYMENT
The northern embayment is an extremely shallow environment fringed with man-
groves on the eastern reaches and with a system of seawalled canals to the
south. The canals are deep (10 to 15 feet) but other areas in the embayment
are shallow (2 to 5 feet). An extensive system of mosquito ditches (over-
grown with mangroves) exists between the canals and the shallow embayment.
To the north, the embayment is shielded by a metal sheetpile wall to prevent
direct exchange of heated water from the station's cooling water discharge.
Backflush of the thermal plume into the embayment does, however, occur on an
intermittent basis. The sediments in the embayment are intermixed with clean
sand and shell. The canals, however, contain extremely silty sediments.
Shallow areas of the embayment contain patchy Ruppia (widgeon grass).
Several aquatic studies have been conducted in the embayment area since
1970. The results of a 1976-1977 study (Mahadevan et al., 1977) indicated
benthic species composition and community information in the area were
uniform and similar to the nearshore open Tampa Bay environment. Results
of the 1979 benthic study (Mahadevan et al., 1980) indicated that, in terms
of species composition and faunal similarity, the northern embayment is
similar to the nearshore bay but dissimilar to the open bay. However,
based on community parameters (density, species richness, diversity) the
embayment is quite similar to the open bay.
Analysis of sediment samples performed during the 1976-1977 aquatic study
indicated the embayment substratum is similar to that of the open bay near-
shore environment.
Although plankton have not been sampled in the embayment, plankton popu-
lations for several aquatic species are expected. Results of fish sam-
pling indicated several species of fish (including the black drum, pinfish,
striped mullet, spot, sheepshead minnow) use the embayment as a nursery
3-5
-------
area. The mangrove fringe and shallow waters seem to promote the occurrence
of juveniles in the embayment.
The studies appeared to demonstrate that life stages of locally important game
and sport fish could be found in the embayment, thus indicating movement of
fish in and out of the area.
Based upon these studies and an engineering feasibility review, Location II
would appear to be suitable and acceptable as the release point for the
organism return system.
3-6
-------
Table 3-1. Potential alternative organism return locations
Alternative
Location
Length of
Travel
Cost
($1,000)
Comments
II-Route A
II-Route B
III
1,800'
1,800'
4,900'
8,400'
500
500
1,300
2,500
Gravity Flow, $50,000
Additional for Pumping
Includes Cost of
Sealing Breakwater
IV
6,700'
1,900
3-7
-------
'-AIZm
FISHHOOK
KEY
Figure 3-2. Potential organism release locations.
3-8
-------
Chapter 4
PUBLIC PARTICIPATION
The Draft Environmental Impact Statement (DEIS) was published in July 1981
and was made available to the public on July 10, 1981. The Federal Register,
Volume 46, Number 137, Page 37084, dated July 17, 1981, announced the avail-
ability of the DEIS and the proposed issuance of an NPDES Permit. The DEIS
was provided to various Federal, state, and local agencies, as well as con-
cerned individuals, interest groups, and public officials. A public notice
of the document's availability and of a public hearing on the DEIS appeared
in the Tampa Tribune and the Sarasota Herald Tribune on July 16, 1981.
The public hearing was held in Ruskin, Florida, on August 19, 1981. In
addition to the public input afforded by the hearing (transcript provided
herein), many letters were received and are included in this Final EIS.
The designations in the margins of the letters identify specific comments for
which responses have been developed. These responses follow the letters. In
a similar manner, the designations in the margins of the hearing transcript
identify comments which have received responses. Many of the transcript com-
ments were similar or identical to the written; consequently, some transcript
responses refer to responses to written comments already presented.
4-1
-------
Index to consents on TECO Big Bend Unit 4 DEIS (Sheet I of 6)
Comment
Response
Comment
P«ge
page
number
number
number
Commentor
Date
Nature of comment
Written comments
FDA-1
4-11
4-167
Florida Department of
7/15/81
Recommend TECO contact local
Agriculture and Con-
County Forester when plan-
sumer Services
ning revegetation at site
SCS-I
4-12
4-167
Soil Conservation Service
8/19/81
No comment
DER-1
4-13
4-167
Florida Department of En-
8/20/81
Conditions of certification
vironmental Regulation
DER-2
4-13
4-167
Florida Department of En-
8/20/81
Discharge of wash water from
vironmental Regulation
fine-mesh screens
COE-1
4-15
4-167
U.S. Army Corps of
8/21/81
Dredge and fill permits
Engineers
CDC-1
4-16
4-167
Center for Disease Control
8/27/81
Vector-borne diseases and
control program
CDC-2
4-16
4-167
Center for Disease Control
8/27/81
Variance to water quality
standards
CDC-3
4-17
4-168
Center for Disease Control
8/27/81
Thermal plume and discharge
canal
CDC-4
4-17
4-168
Center for Disease Control
8/27/81
Unused cooling pond
CDC-5
4-17
4-168
Center for Disease Control
8/27/81
Impacts on mangrove area
CDC-6
4-17
4-169
Center for Disease Control
8/27/81
Impacts on manatee
WMD-1
4-19
4-169
Southwest Florida Water
8/31/81
Supports siting plant on coast
Management District
WMD-2
4-19
4-169
Southwest Florida Water
8/31/81
Consumptive use of freshwater
Management Distict
-------
Index to comments on TECO Big Bend Unit 4 DEIS (Sheet 2 of 6)
Comment
Response
Comment
page
page
number
number
number
Commentor
Date
Nature of comment
Written comments (continued)
TECO-1
4-21
4-169
Tampa Electric
Company
9/1/81
Acoustic impacts
TECO-2
4-22
4-169
Tampa Electric
Company
9/1/81
Chlorine residuals
TECO-3
4-23
4-170
Tampa Electric
Company
9/1/81
Variance to water quality
standards
TECO-4
4-25
4-170
Tampa Electric
Company
9/1/81
Alternate treatment system for
metals
TECO-5
4-26
4-170
Tampa Electric
Company
9/1/81
Liner of fly-ash pond
TECO-6
4-26
4-170
Tampa Electric
Company
9/1/81
EPA recommended mitigative
measures
TECO-7
4-27
4-170
Tampa Electric
Company
9/1/81
Noise impacts
TEC0-8
4-27
4-170
Tampa Electric
Company
9/1/81
FGD blowdown discharge
TECO-9
4-28
4-170
Tampa Electric
Company
9/1/81
Ground-water monitoring program
TECO-IO
4-28
4-171
Tampa Electric
Company
9/1/81
Variance to water quality
standards
TECO-11
4-29
4-171
Tampa Electric
Company
9/1/81
Net limits for discharges from
slag pond
TECO-12
4-29
4-171
Tampa Electric
Company
9/1/81
Variance to water quality
standards
TECO-13
4-30
4-171
Tampa Electric
Company
9/1/81
Correction to discussion of
BACT
TECO-14
4-31
4-171
Tampa Electric
Company
9/1/81
Conformance to NSPS for air
quality
TECO-15
4-31
4-171
Tampa Electric
Company
9/1/81
Sulfur dioxide potential
emission rate
TECO-16
4-31
4-171
Tampa Electric
Company
9/1/81
Final Conditions of
Certification
TECO-17
4-32
4-171
Tampa Electric
Company
9/1/81
Update copy of Chapter 17-3
-------
Index to comments on TECO Big Bend Unit 4 DEIS (Sheet 3 of 6)
Comment
Response
Comment
page
page
number
number
number
Commentor Date
Nature of comment
Written comments (continued)
HEC-1
4-89
4-171
Hillsborough Environmental
9/1/81
Conservation
Coalition
HEC-2
4-91
4-192
Hillsborough Environmental
9/1/81
Clarification of some SO2
Coalition
information
HEC-3
4-91
4-192
Hillsborough Environmental
9/1/81
Clarification of some particu
Coalition
late matter information
HEC-4
4-92
4-192
Hillsborough Environmental
9/1/81
Impacts of acid rain
Coalition
HEC-5
4-92
4-193
Hillsborough Environmental
9/1/81
Impacts of thermal discharges
Coalition
HEC-6
4-92
4-194
Hillsborough Environmental
9/1/81
Impacts of heavy metals in
Coalition
solid waste
HEC-7
4-92
4-194
Hillsborough Environmental
9/1/81
Add fine-mesh screens to
Coalition
Units 1 and 2
DOI-1
4-92
4-194
U.S. Department of the
9/3/81
Mineral resources in area
Interior
DOI-2
4-98
4-194
U.S. Department of the
9/3/81
Impacts on manatee
Interior
CR-1
4-98
4-195
Clearinghouse Review
9/4/81
Project conforms to Areawide
Water Quality Management
Program
CR-2
4-100
4-195
Clearinghouse Review
9/4/81
Minimization of impacts
CR-3
4-100
4-195
Clearinghouse Review
9/4/81
Socioeconomic impacts
CR-4
4-100
4-195
Clearinghouse Review
9/4/81
Minimization of impacts, con-
tinued biological studies
recommended
-------
Index to comments on TECO Big Bend Unit 4 DEIS (Sheet 4 of 6)
Comment
Response
Comment
page
page
number
number
number
Commentor
Date
Nature of comment
Written comments (continued)
CR-5
4-102
4-195
Clearinghouse Review
9/4/81
Compatibility with existing
plans
SC-1
4-103
4-195
Sierra Club
9/14/81
Impacts on marine biota
SC-2
4-103
4-195
Sierra Club
9/14/81
Hydrothermal mathematical
model of discharge plume
SC-3
4-103
4-195
Sierra Club
9/14/81
Water quality impacts
SC-4
4-103
4-195
Sierra Club
9/14/81
Section 316 Demonstration
SC-5
4-103
4-196
Sierra Club
9/14/81
Conservation as an alternative
SC-6
4-103
4-196
Sierra Club
9/14/81
Conservation and renewable re-
sources as alternatives
SC-7
4-103
4-196
Sierra Club
9/14/81
Conservation as an alternative
Transcript comments
TECO-1
4-226
4-273
Tampa Electric Company
8/19/81
Air quality impacts
TECO-2
4-226
4-273
Tampa Electric Company
8/19/81
Air quality impacts
TECO-3
4-227
4-273
Tampa Electric Company
8/19/81
Air quality impacts
GCR-1
4-235
4-273
Gloria C. Rains
8/19/81
Need and conservation
considerations
GCR-2
4-236
4-273
Gloria C. Rains
8/19/81
Overall impacts
GCR-3
4-237
4-273
Gloria C. Rains
8/19/81
Impact on rates
GCR-4
4-237
4-274
Gloria C. Rains
8/19/81
Flooding potential
GCR-5
4-237
4-274
Gloria C. Rains
8/19/81
Air quality impacts
GCR-6
4-238
4-274
Gloria C. Rains
8/19/81
Impacts on surface water and
ground water
GCR-7
4-238
4-274
Gloria C. Rains
8/19/81
Ground-water impacts
GCR-8
4-239
4-277
Gloria C. Rains
8/19/81
Solid waste
-------
Index to consents on TECO Big Bend Unit 4 DEIS (Sheet 5 of 6)
Comment
Response
Comment
page
page
number
number
number
Commentator
Date
Nature of comment
Transcript comments
(continued)
GCR-9
4-239
4-277
Gloria C. Rains
8/19/81
Impacts on surface water and
ground water
GCR-10
4-239
4-278
Gloria C. Rains
8/19/81
Surface water impacts
GCR-11
4-240
4-278
Gloria C. Rains
8/19/81
Variance to water quality
standards
GCR-12
4-240
4-278
Gloria C. Rains
8/19/81
Impacts of thermal plume
GCR-13
4-240
4-278
Gloria C. Rains
8/19/81
Entrainment impacts
GCR-14
4-241
4-279
Gloria C. Rains
8/19/81
Acid rain
GCR-15
4-241
4-279
Gloria C. Rains
8/19/81
Overall impacts
GCR-16
4-241
4-279
Gloria C. Rains
8/19/81
Wastewater treatment
ST-I
4-244
4-279
Sally Thompson
8/19/81
Conservation
RP-1
4-245
4-279
Richard Paul
8/19/81
Acid rain
RP-2
4-245
4-279
Richard Paul
8/19/81
Impacts of thermal plume
RP-3
4-246
4-279
Richard Paul
8/19/81
Impacts of heavy metal
contamination
RP-4
4-246
4-279
Richard Paul
8/19/81
Fine-mesh screens
MK-1
4-246
4-279
Michael Kenney
8/19/81
Air quality impacts
MK-2
4-248
4-279
Michael Kenney
8/19/81
Air quality impacts
MK-3
4-249
4-280
Michael Kenney
8/19/81
Air quality impacts
MK-4
4-249
4-280
Michael Kenney
8/19/81
Air quality impacts
MK-5
4-250
4-280
Michael Kenney
8/19/81
Air quality impacts
LR-1
4-250
4-280
Laurie Rask
8/19/81
Alternative actions and
conservation
-------
Index to comments on TECO Big Bend Unit 4 DEIS (Sheet 6 of 6)
Comment
Response
Comment
page
page
number
number
number
Commentor
Date
Nature of comment
Transcript comments
(continued)
JM-1
4-252
4-280
Julie Morris
8/19/81
General comment
JM-2
4-252
4-280
Julie Morris
8/19/81
Conservation
JM-3
4-253
4-280
Julie Morris
8/19/81
Electrical use patterns
JM-4
4-253
4-280
Julie Morris
8/19/81
Conservation
JM-5
4-254
4-280
Julie Morris
8/19/81
Reserve capacity
JM-6
4-254
4-281
Julie Morris
8/19/81
Conservation and oil
displacement
BC-1
4-257
4-281
Barney Capehart
8/19/81
Alternative energy sources
BC-2
4-257
4-281
Barney Capehart
8/19/81
Conservation
-------
4.1 WRITTEN COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT AND RESPONSES
TO WRITTEN COMMENTS
The written comments received from the following sources are reproduced
in this section:
Florida Department of Agriculture & Consumer Services
U.S. Soil Conservation Service
Florida Department of Environmental Regulation
Corps of Engineers
Center for Disease Control
Southwest Florida Water Management District
Tampa Electric Company
Hillsborough Environmental Coalition
U.S. Department of the Interior
Clearinghouse Review
Sierra Club
Responses to these comments are also included.
4-9
-------
*CON.^
™ c. f' ^ J«nO J FLORIDA DEPARTMENT OF AGRICULTURE S CONSUMER SERVICES
'vL-0'
DOYLE CONNER COMMISSIONER * DIVISION OF FORESTRY / COLLINS BUILDING / TALLAHASSEE 32304
FREP
EIS
POWER PLANTS,
SUBSTATIONS, ETC.
July 15, 1981
Mr. Dario J. Dal Santo
EIS Project Officer
U. S. Environmental Protection Agency
Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30365
Dear Mr. Dal Santo:
This is in response to your recent transmittal of the Draft
Environmental Impact Statement for the proposed construction of a new
electrical generating plant, Big Bend Unit 4, Tampa Electric Company.
We have reviewed the document for forestry and have no particular
problems with the proposal. We suggest Tampa Electric contact our FDA-1
local County Forester, Robert Der, when they begin to lay-out their
landscape proposals. He nay be able to assist them with native trees
from our nurseries and advice on planting them. He may be reached at
5339 SR579, Seffner, Florida, 33584 (telephone: 813/621-5605).
We appreciate the opportunity to review the draft EIS. If we can
be of any assistance, feel free to call on us.
*"s.
Sincerely yours, '
:-T ^ /Vl't ^ c /
George L. Reinert, Chief
Forest Resource & Economic Planning Bureau
cc: District Forester Mark Hebb, Lakeland
County Forester Robert Der, Seffner
4-11
-------
United States Soil State Office
Department of Conservation D n 7no
Agriculture Service °* Box LlUti
Gainesville, FL 32602
August 19, 1981
Dario J. Dal Santo
EIS Project Office
EPA-Region IV
345 Courtland Street, NE
Atlanta, GA 30365
SCS-1
Dear Mr. Dal Santo:
We have no comments concerning the draft Environmental Impact Statement for
Tampa Electric Company, Big Bend, Unit 4.
Sincerely,
fames W. Mitchell
State Conservationist
cc:
Norman A. Berg, Chief, Soil Conservation Service, USDA, Washington, D.C.
A The Soil Conservation Service
Jj. is an agency of the
Department of Agriculture
4-12
SCS-AS-1
10-79
-------
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWIN TOWERS OFFICE BUILDING
2600 BLAIR STONE ROAO
TALLAHASSEE. FLORIDA 32301
- )]\\
BOB GRAHAM
GOVERNOR
VICTORIA J. TSCHINKEL
SECRETARY
August 20, 1981
Mr. Walter Kolb
Senior Governmental Analyst
Office of Planning and Budgeting
Office of the Governor
415 Carlton Building
Tallahassee, Florida 32301
Re: DEIS - Tampa Electric Company.
Big Bend Unit 4, SAI FL8107230120-E
Dear Mr. Kolb:
The Department of Environmental Regulation has reviewed
the Draft Environmental Impact Statement for TECO's Big Bend
Unit 4. This power plant unit was reviewed and certified pur-
suant to the Florida Electrical Power Plant Siting Act. On
August 4, 1981, the Governor and Cabinet sitting as the Siting
Board approved the certification of the coal-fired unit.
In reviewing the DEIS we noted that page F-ll does not
correspond exactly to page 8 of the existing conditions of cert- DER-1
ification for Big Bend 4. A correct copy of that page is cbdata
attached. It was also noted that pages G-5 through G-8 are ERRATA
duplicates of pages G-l through G-4,
The draft NPDES permits for Big Bend Unit 4 and for Units
1-3 contained in Appendices A and B respectively do not speci-
fically provide for discharge of fine mesh screen washwater and
organisms to the Organism Return Canal. However, a provision DER-2
for this discharge is made in DER Condition XXVIII as shown on
ENVIRONMENTAL .W-^CT STATEMENT
BRANCH
|(?rar?nn nr?i
4-13
Protecting Florida and Your Quality of Life
iiLUaiyj u iy
REGION IV - EPA
-------
page F-25 of the DEIS. As DER will submit a 401 water quality
certification to EPA contingent upon inclusion of the Conditions
of Certification approved by the Governor and Cabinet, this
issue will be addressed.
HS0:sb
cc: John Qutland
Mickey Bryant
Dario Dal Santo
Charles Kaplan
Sincerely,
Hamilton S. Oven, Jr., P.E.
Administrator
Power Plant Siting
4-14
-------
DEPARTMENT OF THE ARMY
JACKSONVILLE Dl STRICT. CORPS OF ENGINEERS
P. O. BOX 4970
JACKSONVILLE. FLORIDA 32232
SAJPD-ES
21 August 1981
Mr. John E. Hagan, III
Chief, EIS Branch
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
In reference to Public Notice No. PH81FL167, dated July 16, 1981, pertaining
to the Draft Environmental Impact Statement on Tampa Electric Company's
proposed Big Bend Unit Number 4 to be constructed near Tampa in Hillsborough
County, Florida (NPDES FL0000817/FL0037044), the Corps of Engineers is COE-1
preparing to take final action on the dredge and fill permits noted on page
IX as soon as notification that the EIS has been filed is published in the
Federal Register. Restoration of Jackson Branch is included in the permit
along with the indicated intake and discharge structures.
Sincerely,
A. J. SALEM
Acting Chief,
Planning Division
4-15
-------
^ 1 " h \\ ; ri\puti!,c He.jtth Service
Centers for Disease Control
A{'®^GS?»3$f
August 27, 1981
Mr. John Hagan
Chief, EIS Branch
U.S. Environmental Protection
Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: FL0000817 and/or FL0037044
Dear Mr. Hagan:
We have reviewed the Draft Environmental Impact Statement (EIS) for the Proposed
Issuance of a New Source National Pollutant Discharge Elimination System Permit
to Tampa Electric Company - Big Bend Unit 4 in Hillsborough County, Florida. We
are responding on behalf of the Public Health Service and are offering the fol-
lowing comments for your consideration in preparing the final document.
It is important that this proposal not be allowed to increase any local vector
populations capable of causing vector-borne disease or nuisance problems. The
EIS should include a historical discussion of vector-borne disease and nuisance
CDC-1 problems that have occurred in the area and the local efforts to mitigate these
problems. In view of the potential vector habitat areas to be created by the
applicant, we recommend that a vector control management plan be developed by
the applicant and that it be approved by the local health department. The EIS
should address the project's potential vector-borne impacts and include a
commitment that a vector control management plan will be developed and implemented
by the applicant for the life of the project.
According to the EIS, ambient levels of several metals in Hillsborough Bay and
in the intake canal violate State of Florida Water Quality Standards. Since
the discharge of these waters, after using them for cooling purposes, would
also violate applicable water quality standards, the applicant has applied for
a variance from the standards in order to have a discharge that does not violate
applicable standards. Is this variance for the point of discharge or for the
boundary of a mixing zone? Will the variance be written in such a way that no
degradation of ambient water quality (with the exception of a thermal mixing
CDC-2 zone) will be permitted at the point of discharge? If so, will the variance
be flexible enough to demand an improvement in the quality of the discharge
if an improvement occurs in the quality of the intake water?
We understand that the applicant's proposed waste heat rejection system is
once-through cooling with fine-mesh screens on Units 3 and 4 and no dilution.
Waters, after passing through the condenser, will exit to the existing discharge
channel and combine with discharge waters from Units 1, 2 and 3. Inspection
4-16
-------
Page 2 - Mr. John Hagan
of the isothermal contour maps (Figures 3-37 and 3-38) reveal as much as a
7 to 8 degree rise in temperature at the point of discharge. Do the iosthermal
maps realistically depict the expected thermal plume configuration? Is any CDC-3
portion of the thermal plume expected to hug the shore? The EIS should describe
how the expected plume relates to the designated mixing zone and whether the
temperature rise at the boundary of the mixing zone will comply with Subsection
17-3.05 (l)(c)(ii), Thermal Surface Water Criteria, of the Florida Water Quality
Standards.
We believe the EIS should evaluate the effect that the westerly discharge has
upon the quality and circulation of embayment waters between the discharge
channel of Big Bend and Apollo Beach. The isothermal contour maps (Figure
3-37) reveal thermal mixing to occur only westward of Apollo Beach. Will or
is the "discharge channel" designed to prevent any mixing in the embayment even
during tide changes? Several figures in the EIS portray a steel sheet-pile
wall extending along the discharge channel to the mouth of the embayment. Has
consideration been given to extending this wall beyond the mouth of the embay-
ment to preclude unnecessary mixing with embayment waters?
It would also be helpful to explain why the cooling pond shown on Figure 3-7
is to be replaced by a bottom ash disposal pond when interior land is available.
Couldn't this cooling pond continue to provide cooling benefits, especially CDC-4
if it is used in conjunction with the discharge channel?
Please indicate how much of the original mangrove community exists. The EIS
should explain in detail the ecologic significance and relative importance
of the affected mangrove community and the remaining embayment with that of CDC-5
other areas on the coast. The economic and recreational benefits that this
area provides in terms of fisheries (spawning, nursery feeding, fishing
grounds, etc.) and other activities should be highlighted in the EIS. With the
knowledge that tidal currents in Hillsborough are "generally weak", will the
discharge currents (page 2-51) affect the ingress and egress of fauna to and
from the embayment?
Since "use of the area by manatees may increase with the increase in thermal
discharges...", the EIS should address the potential conflicts that might occur
with manatees and motorboats as development increases in Apollo Beach. Since CDC-6
the power plant discharge will serve as an attraction for manatee, consideration
should be given now to developing mitigation measures to prevent any possible
future problems from occurring.
We appreciate the opportunity to review this EIS for its relevance to public
health and welfare. Please send us one copy of the final document when it
becomes available. Should you have any questions regarding our comments,
please contact Robert Kay of my staff at (404) 262-6649.
Sincerely yours,
/
~ u. ,t x y- ^ t (¦
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
4-17
-------
BRUCE A. SAMSON. Chairman. Tampa
Wm. (). STUBBS. JR.. Vic* Chairman. Darir Cii>
JAMF.S CAMPBF.LL. Secretary. Plant Citv
RONALD B. LAMRRRT. Trwiuw. Waurhula
5CMM) U.S. HIGHWAY 41. SOUTH — BROOKSVILLE. FLORIDA 33512
PHONE (0041 :%-T21l
B. T. LONOINO. Saranou
CI.IFF STEPHENS. Oarwairr
DON CRANF.. St. pMrr»b..ri
JIM KlMBRnl'GH. Rrnnkivill*
ARCH I'PDIKfc. JR., Uke W»|,»
WILLIAM C TATL'M. Executive Dirmor
August 31, 1981
Mr. John E. Hagan, III
Chief, EIS Branch
U. S. Environmental Protection Agency
345 Courtland Street, N. E.
Atlanta, Georgia 30365
Re: Public Notice No. PH81FL167
NPDES Nos. FL0000817/FL0037144
Tampa Electric Company's proposed
Big Bend Unit No. 4 Power Plant
Dear Mr. Hagan:
Southwest Florida Water Management District supports Tampa Electric
Company's proposed use of once-through cooling for Big Bend Unit
No. 4 Power Plant in Hillsborough County, Florida.
This District has supported and continues to support the use of
once-through cooling for existing units 1-3 as well.
The Southwest Florida Water Management District is a special regional
water management district and is comprised of part or all of sixteen
counties in the Southwestern part of the state. TECO Big Bend Unit
No. 4 is located in the central portion of our district.
This District, by law and by delegation from the Florida Department
of Environmental Regulation, is charged with the responsibility of
managing the regional water resources. A comprehensive program
regulating and limiting consumptive uses of fresh water within the
district has been in effect since 1975.
The fresh water resources within the district are limited since
the sole source of supply is rainfall. There are no streams or
rivers which carry fresh water into our district from other water-
shed basins. The entire western boundary of the district is
contiguous with tjie Gulf of Mexico and the fresh water aquifers
are all underlain by deeper, highly mineralized, non-potable waters.
In a very real sense, peninsular Florida is hydrologically analogous
to an island at sea. The fresh water available in the ground is a
relatively shallow lens floating on deeper, non-potable water.
4-18
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John E. Hagan, III
August 31, 1981
Page -2-
This portion of the State of Florida has seen a tremendous growth
in population in recent years and a corresponding growth in demand
for consumption and use of the available fresh water resources.
Our best projections indicate that this trend will continue and the
available supply will be ever shrinking. From time to time, site
specific shortages of fresh water have occurred and during especially
dry conditions fresh water use has been limited or curtailed.
All of the foregoing is relevant to TECO Big Bend Unit 4 because it is
against this background that the Governing Board of this District
determined in December, 1973, that it would consistently oppose the
location of electric power generating plants on inland locations.
The large scale consumptive use of limited fresh water supplies for
power plant cooling purposes would prevent use of that same water WMD-1
for other, more beneficial, consumptive and non-consumptive purposes.
The consequences of this" could be far reaching and severe. Instead,
this district supports the location of electric power generating
plants along the coastline and urges each electric utility to use
the virtually unlimited supply of saline and brackish water from the
coastal location for cooling purposes. For this reason, this district
supports TECO's proposed use of once-through cooling for Unit 4, as
well as for existing units 1-3.
This district is also concerned with consumptive uses proposed for
the subject plant other than for cooling purposes. The materials
we have received concerning the proposed environmental impact state-
ment indicate that potable fresh water from the public supply system
of Hillsborough County will be used exclusively for boiler makeup
water and other consumptive uses (aside from cooling exhaust steam).
This portion of the EIS may be somewhat misleading since TECO is
obligated by the final order of the Governor and Cabinet of the WMD-2
State of Florida in the state site certification proceeding to use
the lowest quality water which it has the ability to use. To the
extent that a dependable supply of non-potable water can be provided,
TECO is obliged to use non-potable water in lieu of potable water
whereever possible.
If TECO can demonstrate that non-potable water is not available due
to technical or environmental reasons, then the use of potable water
from the public water supply system of Hillsborough County may be
authorized by the Secretary of DER, upon the concurrence of this
district. We suggest that this portion of the EIS be modified to be
consistent with the site certification order of the Governor and
Cabinet of this state.
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John E. Hagan, III
August 31, 1981
Page -2-
We appreciate the opportunity to provide these comments and urge that
they be considered in the formulation of final determinations
regarding the final environmental impact statement and the proposed
NPDES permits.
Sincerely yours,
WILLIAM C. TATUM
Executive Director
WCT/dl
cc: Lawrence N. Curtin, Esquire
Victoria Tschinkel, Secretary, DER
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COMMENTS OF TAMPA ELECTRIC COMPANY ON DRAFT
ENVIRONMENTAL IMPACT STATEMENT, DRAFT NPDES PERMIT AND
PRELIMINARY DETERMINATION ON THE PSD PERMIT
FOR BIG BEND UNIT NO. 4 AND DRAFT NPDES
PERMIT FOR BIG BEND UNITS 1, 2 AND 3
I. EXECUTIVE SUMMARY
Section 4., Page X, Paragraph 2 - The last sentence TECO-1
of this paragraph notes that acoustic impacts should be min-
imal and would be associated primarily with setting of the
steam valves. In addition"to this activity, Tampa Electric
Company will engage in a steam blowing operation prior to
initial startup of Unit No. 4. The steam blowing activity
is recommended by the manufacturer to insure against damage
to the steam turbine upon startup of the Unit. The entire
steam blowing operation occurs only once in the life of the
plant and will span a period not to exceed 30 days. Since
it is not possible to accurately predict the noise levels
that will be experienced during the steam blowing operation,
Tampa Electric Company requested a variance from
Hillsborough County Environmental Protection Commission
noise regulations in the State Site Certification proceed-
ings held pursuant to the Florida Electrical Power Plant
Siting Act. On August 17, 1981, the Florida Governor and
Cabinet entered an order certifying the construction and
operation of Big Bend Unit No. 4 and granting a variance
from the Hillsborough County Environmental Protection noise
4-21
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regulations for a period not to exceed thirty days from the
commencement of the steam blowing operation. A copy of the
order and the final Conditions of Certification is attached
(Attachment 1). In addition to the variance, Tampa Electric
Company will engage in a public awareness campaign prior to
commencing the steam blowing activity to forewarn the public
of the estimated time and duration of the noise.
TECO-2 Section 4., Page XI, Paragraph 3 - The discussion
indicates that chlorine will be used to prevent biofouling
of condenser tubes and will be discharged at maximum levels
of 0.2 mg/1, expressed as total residual oxidants (TRO).
The discussion also notes that detailed die-away studies are
to be conducted prior to the Final Environmental Impact
Statement to assure that a 0.01 mg/1 TRO level can be
achieved in the 6.1 acre discharge canal. The 6.1 acre
figure refers to the size of the chlorine mixing zone that
has been recommended by the Florida Department of
Environmental Regulation and approved by the Florida
Governor and Cabinet on August 17, 1981, rather than the
size of the discharge canal. This mixing zone is entirely
contained within the discharge canal for the Big Bend
Station. On July 16, 1981, after release to the public of
the Draft Environmental Impact Statement, Tampa Electric
Company began work on the die-away study. The Company began
taking chlorine readings on the second day of the study.
4-22
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Chlorine residuals at the point of discharge were not
detectable. Further testing at increased chlorine feed
rates yielded the same results. After consideration of
these results and discussions with representatives of Region
IV of the Environmental Protection Agency (EPA), the study
was terminated. It was concluded that the high intake tem-
perature of the water along with extreme biological activity
in the circulating water intake created a considerably high
chlorine demand^in the condenser cooling water, such that no
chlorine was detectable in the discharge canal. Due to the
circumstances encountered during the test, Tampa Electric
Company proposed to EPA representatives to suspend all ef-
forts to continue with the chlorine die-away study until
chlorine residuals are read at the point of discharge as in-
dicated by routine weekly monitoring reports.
TECO-3 Section 6, Page XIII - The discussion indicates
that Tampa Electric Company is pursuing a variance request
from certain Florida water quality standards criteria with
the Florida Department of Environmental Regulation and the
EPA. It further notes that a preliminary recommendation for
approval of a two-year variance has been received, but that
the approval has not yet been finalized. Since release of
the Draft Environmental Impact Statement, the Florida
Governor and Cabinet on August 17, 1981, approved a two-year
variance from the Florida water quality standards for dis-
4-23
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charges from Unit No. 4 as requested by Tampa Electric
Company. This is the final state approval required for
variance relief for Unit No. 4 (See Attachment 1). Tampa
Electric Company has also received a Recommended Order from
the State Hearing Office assigned the variance matters
recommending that the variance request for the discharge
from the Units 1, 2 and 3 slag pond be granted by the
Florida Department of Environmental Regulation. A copy of
this Recommended Order is attached (Attachment 2). Final
approval has not yet been received from the Department of
Environmental Regulation, but is expected in the near
future.
In the second paragraph under this section, it is
noted that the Company is pursuing a variance request from
local water quality standards through the Florida Department
of Environmental Regulation and the Hillsborough County
Environmental Protection Commission and that this issue is
unresolved. For Unit No. 4, the August 17, 1981, order of
the Governor and Cabinet also grants the variance from
Hillsborough County Environmental Protection Commission
water quality standards. This approval has been granted for
the life of the Big Bend Unit No. 4 facility certification
and is the final approval necessary for that variance
request.
4-24
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The third paragraph under Section 6 indicates that
the proposed level of chlorine discharges of 0.2 mg/1 ex-
pressed as total residual oxidants (TRO) has not yet been
resolved as being an acceptable limitation to adequately
protect the aquatic organisms in the Big Bend Station dis-
charge canal. We note that the Florida Governor and Cabinet
approved the limit of 0.2 mg/1 for Big Bend Unit No. 4.
II. CHAPTER 2
ERRATA Page 2-23, Figure 2-4 - This figure is the plot
plan for the Big Bend Station and contains the locations of
each NPDES outfall from the station. Outfall No. 001 is in-
correctly located on this figure and the location should be
modified as reflected in red on the attached plot plan
(Attachment 3).
ERRATA Page 2-24, Figure 2-5 - This figure is the plant
water balance for the Big Bend Station. This figure does
not reflect the most up-to-date water balance for Big Bend
Unit No. 4. The correct water balance is contained in the
Draft NPDES Permit, Appendix A, Page A-13, of the Draft EIS.
TECO-4 Section 2.7, Pages 2-61,2-62 - The last paragraph
of this section on Pages 2-61 and 2-62 includes a discussion
of the variance request from Florida water quality standards
criteria for Big Bend Unit No. 4 that was approved by the
Florida Governor and Cabinet as a part of the Site
4-25
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Certification for the Unit. This discussion states that the
reevaluation of a filtration system to treat the metals
which are the subject of the variance is under
consideration. The Conditions of Certification which were
approved by the Governor and Cabinet state that Tampa
Electric Company will explore the practicability of treating
the boiler blowdown in the Flue Gas Desulfurization system
treatment system when there is capacity in the system to ac-
commodate that blowdown. The variance conditions do not
contain a discussion of reevaluation of filtration systems
to treat the metals (See Attachment 1).
TECO-5 Section 2.1. Page 2-62, Paragraph 1 - The discus-
sion indicates that the fly ash area will be lined with an
impermeable material to prevent leachate contamination.
Tampa Electric Company has stated that it will line the fly
ash area with a material which has a permeability no greater
_7
than 10 centimeters per second. This is generally consid-
ered to be impermeable.
TECO-6 Section 2.7, Page 2-62, Paragraph 2 - This section
contains a list of six separate mitigative measures not in-
cluded as a part of Tampa Electric Company's project propo-
sal but which are specifically recommended by EPA. The lan-
guage of recommendations 4 and 6 in the text on this page
differs from the language contained in the conditions in the
Draft NPDES permit. This language should be made consistent
4-26
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with that contained in the conditions of the Draft NPDES
permit in Appendix A of the Draft EIS.
III. CHAPTER 3
TECO-7 Section 3.1.2.3, Page 3-4 - This section contains a
discussion of the noise impacts expected to be experienced
during construction of Big Bend Unit No. 4. We note that
the steam blowing operations referenced above have not been
discussed. These operations, for which a final variance
from Hillsborough County Environmental Protection Commission
noise regulations has been granted by the Florida Governor
and Cabinet, will occur only once during the life of the
Unit during a period not to exceed thirty days prior to ini-
tial startup. Tampa Electric Company will engage in a pub-
lic awareness campaign prior to this activity to forewarn
the public of the estimated time and duration of the noise.
IV. APPENDICES
TECO-8 Appendix A, Page A-10 - Condition F. prohibits the
discharge to waters of the United States of low volume
wastes. We note that Flue Gas Desulfurization system blow-
down will be discharged from Big Bend Unit No. 4 and that
the draft permit elsewhere provides for this discharge. The
Flue Gas Desulfurization system blowdown is considered to be
4-27
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a low-volume waste. Accordingly, this condition should be
modified to reflect that Flue Gas Desulfurization system
blowdown may be discharged to the circulating water system
and then to the discharge canal in accordance with the limi-
tations contained on Page A-74 of Appendix A for outfall
No. Oil.
TECO-9 Appendix A, Page A-10 - Requirement No. H. states
that the Permittee shall implement a groundwater monitoring
program approved by EPA and the State of Florida not later
than one year prior to operation of Big Bend Unit No. 4 and
that a detailed plan must be submitted prior to issuance of
the Final EIS. Tampa Electric Company submitted a ground-
water monitoring program to EPA for approval on July 28,
1981.
TECO-10 Appendix A. Page A-16 - Paragraph G. on this page
contains a discussion of the Florida water quality standards
criteria for which variance relief was requested by Tampa
Electric Company. The discussion indicates that the State
of Florida proposed to grant the variance for a two-year
period and require that certain evaluations be performed.
Since the Draft EIS was released to the public, the Florida
Governor and Cabinet entered an order approving the certifi-
cation of the site and granting the variance request of the
Company. This is the final approval necessary for the
variance. The language contained in Section G. should be
4-28
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amended to reflect the conditions imposed on Tampa Electric
Company in the final Conditions of Certification. The ap-
propriate language is found on Page 23 of the final
Conditions of Certification which are attached to these com-
ments (See Attachment 1).
TECO-11 Appendix B, Page B-5 - The limitations proposed for
outfall No. 002 include net limitations for discharges of
total suspended solids from the slag pond. Data collected
subsequent to the establishment of the proposed net limita-
tions have indicated the need to incorporate a provision in
the final Draft NPDES permit that will allow for adjustment
of the net limitations, either by increasing or decreasing
those limits, when data indicate an 'adjustment is warranted.
This issue will be addressed in more detail in a separate
letter from Heywood A. Turner to Howard D. Zeller. We
request that language be incorporated into the final Draft
NPDES permit that authorizes adjustments to the net
limitations.
TECO-12 Appendix B, Pages D-23, D-24 - Section II.B.I, con-
tains a discussion of limitations for the slag pond dis-
charge for existing Units 1, 2 and 3. That discussion indi-
cates that Tampa Electric Company has requested a variance
from certain water quality standards criteria from the State
of Florida, Department of Environmental Regulation. It is
also noted that the staff of the Department of Environmental
4-29
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Regulation proposed to grant the variance for a period of
two years. On June 23, 1981, a public hearing on Tampa
Electric Company's variance request for Units 1 2, and 3 was
held before State Hearing Officer Diane D. Tremor. On
August 5, 1981, Hearing Officer Tremor entered a Recommended
Order which recommends granting the variance relief
requested by Tampa Electric Company. A copy of this
Recommended Order is attached hereto (Attachment 2).
Although the Florida Department of Environmental Regulation
has not finally acted on the variance request, it is ex-
pected that approval will be granted in the near future.
The language contained in Section II.B.I, should be amended
to reflect the recommendation of the Hearing Officer, as
adopted by the Florida Department of Environmental
Regulation.
TECO-13 Appendix E, Page E-5 - In the discussion of best
available control technology (BACT) for NO^ and CO, the sen-
tence "An attachment to this preliminary determination sum-
mary specifies combustion control requirements to balance
the tradeoffs between NO^ and CO emissions through the use
of a flue gas oxygen or C02 monitor ..." should be deleted
since the attachment and requirements have been deleted from
the preliminary determination as noted in EPA's response to
Comment No. 3 on Page E-23.
4-30
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TECO-14 Appendix E, Page E-14 (Condition No. 11) - The ap-
plicant will demonstrate compliance with new source perform-
ance standards requirements for percent reduction of poten-
tial sulfur dioxide emissions by monitoring coal character-
istics and flue gas sulfur dioxide content and through other
procedures established in 40 C.F.R., Subpart Da as discussed
on Page E-4 of Appendix E. The BACT analysis assumed a 25%
reduction in potential sulfur dioxide emissions (not sulfur)
through coal washing and preparation. This assumption was
based on coal washing data indicating 25% reduction is
possible. However, should the coal washing and preparation
not always provide 25% or greater reduction in potential
sulfur dioxide emissions, flexibility has been designed into
the control equipment to achieve an overall reduction in
potential sulfur dioxide emissions of 90%. For these reas-
ons, Condition No. 11. should be deleted.
TECO-15 Appendix E, Page E-17, Table 1 - The potential
emissions of sulfur dioxide should be 15,552 tons per year
to reflect the 0.82 pounds of sulfur dioxide per million
BTU's of heat input emission rate.
TECO-16 Appendix F - Appendix F contains the Conditions of
Certification for Big Bend Unit No. 4 recommended by the
Department of Environmental Regulation as revised as of June
2, 1981. We note that these are not the most recent condi-
tions and that the final Conditions of Certification as ap-
4-31
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proved by the Florida Governor and Cabinet are attached to
these comments (See Attachment 1).
TECO-17 Appendix K - Appendix K contains a reprint of
Chapter 17-3, Florida Administrative Code, apparently cur-
rent as of October 19, 1979. This is not the most up to
date version of Chapter 17-3, Florida Administrative, and
the Appendix should be revised to reflect the current
Department of Environmental Regulation rules.
4-32
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A TTACHdEW
BEFORE THE GOVERNOR AND CABINET
OF THE STATE OF FLORIDA
In The Matter Of: TAMPA ELECTRIC n
COMPANY POWER PLANT SITING APPLICATION, (
BIG BEND STATION UNIT #4 P.A. 79-12. j Case No. 80-1723
)
The following persons were present and participated in
the disposition of this matter:
Honorable Bob Graham
Governor
Honorable George Firestone
Secretary of State
Honorable Jim Smith
Attorney General
Honorable Bill Gunter
Treasurer and Insurance Commissioner
Honorable Gerald A. Lewis
Comptroller
Honorable Doyle Conner
Commissioner of Agriculture
Honorable Ralph D. Turlington
Commissioner of Education
FINAL ORDER ADOPTING HEARING OFFICER'S
RECOMMENDATION OF CERTIFICATION SUBJECT TO CONDITIONS
BY THE GOVERNOR AND CABINET:
The Governor and Cabinet, having heard presentation by the
parties, reviewed the Recommended Order dated July 21, 1981,
(attached and incorporated as Exhibit 1) as well as the special
and general conditions referred to therein and attached thereto
as Appendix I, and being otherwise fully advised herein, it is,
ORDERED:
1. The Recommended Order is approved and adopted.
2. The general and special conditions referenced therein
ind attached thereto as Appendix I are approved and adopted,
and the certification of Big Bend Station Unit ^4 is made
specifically subject to those general and special conditions.
4-33
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DONE AND ENTERED this 17 day of August 1981, subsequent
to a vote of the Governor and Cabinet at a duly constituted
Cabinet meeting of August 4, 1981.
FILING AND ACKNOWLEDGEMENT TOR GOVERNOR AND FLORIDA CABINET:
FILED, on this date, pursuant to S120.52 (9),
fionda Statutes, with the designated«dteP3rT
merit Clerk, receipt of which is hereby ackriow,
/\eed' ^ o o "fcBUUil
fo XtMdn BUSUd
-------
STATE OF FLCkiZ'A
DIVISION OF ADMINISTRATIVE i-EARINGS
RE: T.V-1PA ELECTRIC COMPANY POWER )
PLA\T SITING APPLICATION, BIG ) ,,
BEND STATION UNIT 4 ?.A. 79-12 ) Lase BU-172J
)
RECOMMENDED ORDER
Pursuant to notice, an administrative hearing was
hold before Diane D. Tremor, Hearing Officer with the Division
of Adr.inistrative Hearings, on June 23, 1981 , at the Hillsborough
County Courthouse in Tampa, Florida. The issue for determination
at the hearing was whether the power plant siting application of
Tcim:jo Electric Company for Uie construction and operation of an
electrical generating facility known as Big Bend Unit Number 4
cro'-o^ed for Hillsborough Count:' should be granted.
APPEARANCES AT THE HEARING
For TECO: Lawrence N. Curtin
and Robert P. Murray
Holland and Kr.ight
Post Office Drawer BW
Lakeland, Florida 33302
For DER: Louis F. Hubener
Assistant General Counsel
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
For SWFWf'.D: Thomas E. Cone, Jr.
Blain and Cone, P.A.
202 Madison Street
Post Office Box 399
Tampa, Florida 33601
OTHER APPEARANCES OF RECORD
for Department of Veteran
and Community Affairs: C. Laurence Keesey
Room 204, Carlton Building
Tallahassee, Florida 32301
r ~ | • f
Cci-'jni ss ion : Art;v.:r C. C^iiadav
'Jer.eral Ccur.sc 1
Ful:lic Service Cor..-.iosicr.
1- — as- aair-.es j t r 31
Tall.ih.ir,-.-jo , r Icrida 3 2 2 •"> 1
Prr.T.t i . ?r
- ;:ci
4-35
Exnibit "i
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INTRODUCTION
In August of 1980, Tampa Electric Company (TECO)
filed with the Department of Environmental Regulation its
application for power plant site certification for 3ig 3end
Station Unit ¦! in Hillsborough County, Florida. TECO has
also requested certain variances from the surface water and
ground water quality standards of the Department of Environ-
mental Regulation (DER) and the surface water quality standards
and noise level standards of the Hillsborough County Environ-
mental Protection Commission. This Commission made no appearance
at the hearing. A land use hearing was held on November 17, 1980,
and the Governor and Cabinet, sitting as the Board under Chapter
403, Part II, Florida Statutes, entered an Order on February 19,
1>1S1 , eoncludi n«j that tiio proposed site of Tig Her.d Unit No. 4 is
consistent with existing land use plans and zoning ordinances
and regulations.
Prior to the hearing, the parties filed with the
undersigned a Prehearing Stipulation containing certain stimulated
facts. All issues concerning certification for the proposed
facility were settled by agreement of the parties prior to the
hearing. Subsequent to the hearing, proposed findings of fact,
proposed conclusions of law and a proposed recommendation was
filed with the undersigned. This document constituted the joint
effort of all parties with the exception of the Florida Public
Service Commission which waived further participation in this
proceeding after its order certifying the need fcr Big Bend
Unit No. 4, pursuant to Section 403.519, Florida Statutes.
At the administrative hearing held on June 23, 1981,
TECO presented the testimony of five witnesses and its Exhibits
1 through 29 ware received i~.to dvider.ee. T'.v? witnesses re-
sented by TECD were John 3. ?.ar-.il, an engineer m the Environmental
4-36
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Planning Department at TECO; Wallace Wilchar, TECO's super-
intendent of the Big Bend Station; Steven Marks, accepted as
an expert witness in the area of air quality and dispersion
modolincj; Stephen Jenkins, accepted a.s an expert witness in
the area of pollution control, specifically, flue gas desul-
furization and electrostatic pircipitators; and Jerry L.
Williams, manager of environmental planning for TECO. The DER
presented the testimony of Hamilton S. "Buck" Oven, DER's
administrator ofpower plant sitings, transmission line sitings
and the review section of the Bureau of Permitting. Received
into evidence were DER's Exhibits 1 through 3.
FINDINGS OF FACT
Upon consideration of the stipulations of fact and
the oral and documentary evidence adduced at the hearing, the
following relevant facts are found:
(1) The applicant is a duly authorized and regis-
tered Florida corporation engaged in the business of producing
electrical power for sale. It proposes to construct and operate
a -136 megawatt (gross) coal fired electrical generatinq facility
immediately adjacent to its existing three coal fired units
known as Big Bend Units 1, 2 and 3. The proposed site is located
on the eastern shore of Tampa Bay near the mouth of the Hills-
borough Bay (designated as a Class III waterbody), and is five
miles north of Ruskin, ten miles south of Tampa and fourteen
miles from St. Petersburg across Tampa Bay. As noted, the
proposed unit will be the fourth unit at the applicant's
existing Big Bend site and will share many of the service
facilities with the existing units. The shared facilities include
the coal dock, loading facilities, the coal storage area, the
.switchyard, and t>.e existing wastewater tn-atri'..-".: pend and spray
irrigation field. The exist ma tr.msmi rssion line towers will
4-37
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be used by Unit No. 4, but approximately 3,000 feet of con-
ductors will be installed to connect the new unit to the
existing switchyard located just east of the existing station.
Other associated facilities include storage and handling
facilities for limestone necessary to operate the flue gas
dasulfurization system, storage and disposal, aroas for the by-
product produced by that system and storage and disposal for
ash. A spur from the Seaboard Coast Line Railroad to the site
was constructed for previous projects and will be used in
connection with construction of proposed Unit No. 4. An
additional spur will be constructed entirely within the site
boundaries and no offsite rail construction will be necessary.
2. As a primary energy source, proposed Unit No. 4
will burn high sulfur bituminous coal. The unit will be
equipped with an electrostatic precipitator for the purpose of
controlling the emission of particulates, and will also be
equipped with a flue gas deeulfurization system for the purpose
of controlling emissions of sulfur dioxide. These pollution con-
trol devices have been determined by the Department of Environmental
Regulation to constitute the "b«st available control technology."
In order to prevent significant deterioration of air quality from
the operation of Unit No. 4, various alternative strategies have
been studied by TECO and its consultants. These studies demon-
strate that the most economical strategy which will comply with
state and federal regulations calls for the use of a 99.74*
efficient electrostatic precipitator for the removal of parti-
culate emissions, boiler and burner design for oxides of nitrogen
and carbon monoxide and a system for the removal of sulfur
dioxide which includes a flue ga* desulfuri'zation system, coal
washing and retention of certain of the sulfur dioxide in the
ash during combustion. The entir® sulfur dioxide control system
4-38
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will provide a removal efficiency of 90 percent. Tampa
Electric Company and its consultants have modeled and analyzed
the projected effects of air pollution from proposed Unit No. 4.
The evidence developed from such studies shows that the operation
of L'nit No. 4 as proposed pursuant to the attached conditions
or" certification will comply with State and federal standards
for ambient air quality and the prevention of significant
deterioration of air quality.
(3) nig Bond Unit No. 4 will generate three basic
byproduct materials. These are fly ash, bottom ash and flue
gas desulfurization byproduct. The fly ash generated by Unit
No. 4 will be collected in the electrostatic precipitator
prior to the boiler gas being discharged to the atmosphere.
This material will be marketed as a raw material for the pro-
duction of cement. However, in the event no market is available,
provisions have been made to store fly ash at the site of Unit
No. 4. The unsold fly ash will be sluiced to a settling pond
and then ultimately transported to the final storage area.
Bottom ash is the material resulting from cumbustion of coal
which is collected at the bottom of the boiler. Bottom ash
will be sluiced to a bottom ash area which will consist of a
pond for settling the material and a final disposal area. The
flue gas desulfurization system byproduct, a commerical grade
gypsum, will be stored as necessary on 3ite. It is antici-
pated that this will be a marketable product.
(4) Fresh water necessary to operate the facility,
other than for cooling purposes, will be obtained from Hillsborough
Jounty. This fresh water will be used to supply make-up water to
zr.e boiler and in the flue gas desulfurization system. In
addition, fresh water will be used to sluice ash and to service
tr.e sanitary facilities for the plant, for fire protection and
for other limited miscellaneous uses. All such water will ba
4-39
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obtained off premises and no production wells will be owned or
operated by Tampa Electric Company in connection with Unit No.
4. For some purposes, the applicant will use the lowest quality
of water available from the County before drawing from the
public potable water supply.
(5) Proposed Unit No. 4 will utilize a once through
condenser cooling system and fine mesh screens on the intake
structures will be installed for existing Unit No. 3 and the
proposed Unit No. 4. Saltwater for the cooling system will be
withdrawn from the existing intake canal and will be returned
ta the existing discharge canal. The plant cooling water flow
will be pumped from the intake structure screen wells through
the plant and discharged to the discharge canal where the flow
from Unit No. 4 will comUino with the existing flow from Units
1, 2 and 3. There is sufficient water available in Tampa Bay to
supply the volume requirements of the Unit No. 4 once through
cooling system. The fine mesh screens installed on the intake
structures for existinq Unit Mo. 3 and proposed Unit No. 4 will
minimise the impact of cntrainment and impingement on organisms
in the area. A system will be provided to return organisms
impinged on the fine mesh screen structures to a location suit-
able to the Department o£ Environmental Regulation and the United
States Environmental Protection Agency.
(6) The cooling water passing through the plant
will increase in tsmperature to an expected level of 17 degrees
Fahrenheit above the temperature of the ambient intake cooling
water prior to ultimate dishcharge. This 17 degree temperature
rise i* the design maximum for the unit at maximum load conditions.
The nested water will be discharged to the existing station dis-
charge canal and will then flow in a westerly direction into
the Bay where it will mix with ar.bient water and continue tc
reduce in temperature.
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(7) Tampa Electric Company performed a 316 Demon-
stration in accordance with Section 316 of the Clean Water Act
of 1977, to assess the impacts of the thermal discharge from
the plant on organisms in the Bay. In addition, the effects of
the cooling water intake structure on impingement and entrainment
of organisms in the intake water were assessed. These reports
were submitted to the Department of Environmental Regulation and
the Environmental Protection Agency for evaluation. The Depart-
ment of Environmental Regulation has approved the use of a once
through cooling system with fine mesh screens on the intake
structures of Unit No. 3 and Unit No. 4. DER recommends estab-
lishment of a thermal mixing zone in accordance with Section
17-3.05, Florida Administrative Code, encompassing an area not
to exceed 4980 acres. The conditions of certification proposed
by DER require further validation of the size of the mixing zone
after Unit No. 4 begins operations. The Environmental Protection
Agency has tentatively determined that the use of fine mesh
screen technology on existing Unit No. 3 and proposed Unit No. 4
constitutes the best technology available for minimizing adverse
environmental impacts for the purposes of Section 316(b) of the
Cicun Wjter Act of 1977, and has also tentatively determined
that the impact of the thermal discharge from proposed Unit No. 4
is within acceptable limits under Section 316(a) of the Clean
hnter Act of 1977.
(8) The unit will utilize chlorine in the circu-
lating water system to control the growth of marine organisms
ir. the condenser and intake tunnel. The control of this growth,
or biofoulir.g, is necessary to ensure that the flow of the coo line
water and transfer of heat is not excessively impeded. The
chlorine which is inserted into the circulating sy3ter. is ulti-
mately discharged to the discharge canal and then to the Bay.
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To ensure compliance with Florida Class III water quality
standards applicable to discharges of chlorine, the Department
of Environmental Regulation recommends in its conditions of
certification that an effluent limitation of 0.2 milligrams
per liter be imposed and a mixing zone encompassing 6.1 acres
be established.
(9) Process waste streams associated with Unit No.
4 will include the boiler blowdown, the bottom ash system blow-
down and the flue gas desulfurization system blowdown. These
three waste streams will be discharged to the circulating water
system and ultimately to the discharge canal currently in
existence. Waste streams which are not discharged to surface waters
include the various plant drains and waste waters from various
plant washing operations that will take place. These waste
streams will be collected and transported to the existing waste
water pond and, from there, the waste water will be recycled to
the extent possible. Final disposal of this waste water will
be through the existing stray irrigation system. The existing
waste water pond and spray irrigation field are designed to
accommodate the additional use. Runoff from the coal pile
facility will be contained on the site and transported to the
existing waste water pond.
(10) A drainage system is provided for the plant
for the runoff from the materials storage areas, the byproduct
storage areas, and the construction activity associated with
the main structure at Big Bend Unit No. 4. Materials and by-
product storage area runoff will bo intercepted and contained
on site. Runoff from the Bi? Bend Unit No. 4 main construction
area vi1" be contained and pumped to the waste water por.d. Other
areas subject to construction will employ initiative measures
defined by the conditions of certification attached hereto.
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(XI) A potential concern exists that groundwater
flow from the waste water treatment facilities and byproduct
storage areas may result in leaching of pollutants into the .
groundwaters of the State. The groundwater at the existing site
has been designated as Class 1-B waters. The conditions of
certification include a groundwater monitoring program designed
to assess the ambient water quality and identify the potential
impacts of leachate contamination with respect to the State
groundwater quality standards.
(12) The impact to the existing water quality as a
result of the discharge of the boiler blowdown, bottom ash
blowdown and flue gas desulfurization system blowdown streams
through the circulating water system to the discharge canal and
ultimately to the Bay will be undetectable across the plant, from
the point where the circulating water is taken into the plant,
combined with the three streams and released at the point of
discharge. There will be no measurable change in water quality
as a result of these discharges.
(13) The flue gas desulfurization blowdown stream
and the bottom ash blowdown stream will be subject to treatment
to meet State and federal effluent limitations. The flue gas
desulfurization system will be treated for pH adjustment, sus-
pended solids removal and oil and grease removal prior to discha
The bottom ash system will include an adequately sized pond to
remove suspended solids so that the effluent limitations will be
met. Boiler blowdown will not require treatment to meet appli*
cable effluent limitations. In addition to the treatment method
proposed above, Tar.pa Electric Company evaluated other options
relating to the treatment of these streams to meet water quality
standard* for these discharges. Alternatives investigated incluc
a zero discharge option, further recycling of the waste 3tre«ms
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various treatment methods to remove heavy metals prior to dis-
charge. The cost of these alternatives ranges from $1,2 million
to SI. 8 million. Even with the treatment systems in place, there
will be no detectable change in water quality from the point of
intake to the point of discharge, after addition of the discharges
from the three identified waste streams. Tampa Electric Company
concluded that based upon these factors, and primarily upon the
fact that even with additional treatment there will be no detect-
able change in water quality from the point of intake to the
point of discharge, the expenditures arc not justified in this
circumstance.
(14) Tampa Electric Company requested variances from
orrrnin rc
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contained in Rules 17-3.061 (2) (h) and 17-3.121(7)(lead),
17-3.051 (minimum criteria ) and 17-3.061(2) (general prohibition)
Florida Administrative Code, were withdrawn by TECO at the hearinc
(15) Tampa Electric Company also requested variances
from the Hillsborough County Environmental Protection Commission
rules relating to noise level standards and surface water
quality standards. Mo representative of the Hillsborough
County Environmental Protection Commission appeared at the
hearing.
(16) A variance from the noise level standards con-
tained in the Hillsborough County Environmental Protection Com-
mission's Rule 1-10.04A is requested for the steam blowing operat
that is necessary prior to commercial operation of proposed Unit
-I. Tliiu piucuiiuru is rcc-ununcudud by Uiu uquipmuut manufactur
to minimize damage to the steam turbine resulting from debris
which may accumulate durinq construction of the unit. The noise
levels produced from this steam venting operation vary from unit
to unit and it is impossible to accurately predict what the noise
level* will be. Violation of the provisions of the Commission's
Rule 1-10.04A for short durations during the operation is possibi
Tampa Electric Company will institute a notification procedure
designed to inform residents in the area that the operation will
occur over a shore period of time. Mo adverse impact to resident
and the environment in the affected area is anticiF«te<* and 0Rl-
minor inconvenience to the residents is expected to occur. The
entire operation occurs only intermittantly prior to initial sta:
up of the unit and should encompass a period not to exceed thirt.
(30) days from the start of the steam blowing operation.
(17) The surface water quality rules from which TEC
seeks a variance from the Hillsborough County Environmental
Protection Commission relate to the standards for chromi'um, lea.:
iron ana arsenic for the discharges of boiler Slowdown, botton
ash blowdcwn and flue gas aesulfuri^ation systen blowdcwn front
4-45
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Unit No. 4. This variance request is made for the life of the
certification for Unit No. 4. The evidence demonstrates that
the three waste streams indentifled above are discharged to the
circulating water system and ther. to the discharge canal existing
at the facility. The request for a variance from these pollutant
parameters is based upon data compiled by the applicant and
submitted to the Department of Environmental Regulation which
shows that ambient water quality existing in Hillsborough Bay
contains concentrations of the identified parameters (chromium,
iron, and arsenic) in amounts which are already above applicable
Hillsborough County Enviornmental Protection Commission surface
water quality standards for Hillsborough Bay. The data concerning
lead concentrations is inconclusive. The evidence demonstrates
that with the exception of lead, the maximum values contained in
the applicant's sampling data for chromium, iron, and arsenic
are all above the applicable water quality standards.
(18) Access roads on the site which have been con-
structed for previous projects at the Big Bend Station are
capable of assimilating additional traffic caused by the Unit No. 4
construction activities.
(19). There is very little opportunity for public
access to the site during construction and operation. The vehi-
cular traffic will be intercepted and controlled by a guard
system at the entrance to the site on a 24-hour basis. In addition
all other fenced areas will be equipped with locked gates and
patrolled by roving guards.
(20) Except for intermittent traffic congestion,
plant construction is not expected to have an impact on the nearest
residential communities of Apollo Beach and Adamsville.
(21) There are no historic, scenic, cultural, or
r.atural areas or state parks and recreation areas which will be
disturbed by the construction of 3ig Bend Unit No. 4.
4-46
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(22) The construction of Unit Mo. 4 and its related
facilities will involve the loss of approximately 272 acres of
vegetation and habitat on the eastern shore of Hillsborough Bay,
some of which has been previously disturbed by construction
activities associated with existing Units 1, 2 and 3- Sound
levels predicted as a result of construction activities are
below the maximum permissible sound levels in accordance with
the Hillsborough County noise code limit of 60 dBA during the day-
time a residential area. The majority of construction will
take place during daylight hours and no significant noise impact
is expected at the surrounding residences from onsite construction
activities. Most bird and animal species located near the site
are expected to have adjusted to the existing sound levels rosulti
from Units 1, 2 and 3 operation. Although birds and animals neare
the plant may experience periodic "startle reaction" and move awa:
from the noise source, no measurable effects of construction noist
levels on organisms occurring near or beyond the immediate site
location are anticipated. The area wide effect of construction
and operation on wildlife and vegetation is not expected to be
significant. Appropriate steps have been proposed to minimize
the environmental impact of construction and operation of Unit
Mo. 4.
(23) The Florida Public Service Commission has deter-
nined that thero is a need in the State of Florida for the electr
power to be produced by proposed Big Bend Unit No. 4.
(24) The Tampa Bay Regional Planning Council has
generally concluded that there are no over-riding objections to
the proposal for Unit No. 4 so long as adequate steps are taken
to mitigate problems associated with air and water pollution.
(25) The Hillsborough County City-County Planning
Commission has commented on the project and cffared no objection.-
co it.
4-47
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(26) The Division of Archives. History and Records
Management concluded that the proposed coal fired power plant
is unlikely to affect any archeological or historical sites.
(27) The National Marine Fisheries Service has
made several recommendations regarding or.ce through cooling
concerns including the use of fine mosh .screens, but does not
object to the overall project. The United States Fish and
Wildlife Service expressed concerns similar to those of the
National Marine Fisheries Service and also does not object to
the overall project.
(28) The Department of Veteran and Community Affai:
has concluded that the application is generally compatible with
the State Comprehensive Plan.
(29) The Department of Environmental Regulation ha
made no recommendation concerning the grant or denial of the
variance requests frcm Hillsborough County Environmental Protect
Commission Rules.
(30) The Department of Environmental Regulation,
the Department of Veteran and Community Affairs and the Southwe
Florida Water Management District have all recommended certific
of the proposed Big Bend Unit No. 4 subject to the stipulated c
ditions of certification which are attached to this Recommendec
Order.
(31) At the conclusion of the site cartificatior.
hearing, members of the general public were given the opportun
to comment upon the application for site certification. No
public testimony was offered.
CONCLUSIONS OF LAV.'
This proceeding was conducted pursuant to the "Fic
F.lcctrical Power Plant Sitincj Act," Chapter 402 , Part :i, Floi
Statutes, and Chaster 17-17, Florida Adrair.istracive Code, to
aider Tampa Electric Company's application for site cercifica
of nroponed Sivt >nd (.'nit "o. 4. m .vsc r3ar.ee w i-.lt Chapters
4-48
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*nd 120, Florida Statutes, and Chapter 17-17, Florida Adminis-
trative Code, notice was given to all persons and parties entitl
thereto, as well as to the general public.
The purpose of the site certification hearing was tc
receive testimony and evidence concerning whether tho location
and operation of the proposed facilities will produce minimal
adverse effects on human health, the environment, the ecology
of the land ?and its wildlife, and the ecology of state waters
and their aquatic life in an effort to fully balance the increas
demand for electric power plant location and operation with the
broad interests of the public. Section 403.502, Florida Statute
The record of this proceeding establishes that all
the necessary and required governmental agencies wore parties tc
this proceeding and that all required reports and studies were
completed and presented to the Department of Environmental
Regulation. These include the report of the Department of Vete:
and Community Affairs as to the compatibility of the proposed
electrical power plant with the State Comprehensive Plan ($403..
(a) , Fla. Stats.), the Florida Public Service Commission's repo:
as to the present and future need for the electrical generating
capacity to be supplied by the proposed plant (§403.507 (1) fb),
Fla. Stats.), and the report of the Southwest Florida Water
Management District as to its position on the impact of the pre
posed facility or. water resources (iiule 17-17.04(5), Fla. Admir..
The record further establishes that the Department of Environme
Regulation conducted or contracted for the enumerated studies
required by Section 403.507(2), Florida Statutes, and completed
its report and recommendations with respect thereto. The Depar
ment of Environmental Regulation recommends certification of
•proposal Big Send Unit :;o. 4 subject to the attached condition;
of certification which have been accepted by the applicant Tarrr
Zlectric Company.
4-49
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The oral and documentary evidence adduced at the
hearing demonstrate that the operational safeguards for the
proposed Unit No. 4 are technically sufficient for the welfare
and protection of the citizens of Florida. If performed in
accordance with the attached conditions of certification, the
construction, operation and location of the proposed new unit
.ire expected to produce minimal adverse effects on human health,
the environment, the ecology of the land and its wildlife and
the ecology of State waters and their acu&tic life. Certification
is consonant with tho premise of abundant, low-cost electrical
energy. If certified pursuant to.the attached conditions, pro-
posed Big Bend Unit No. 4 will comply with pertinent State and
federal regulations concerning ambient air quality, the pre-
vention of significant deterioration of air quality and the
application of the "best available control technology."
The applicant's request for a variance from the
DER's surface water quality standards for discharges of boiler
blowdown, bottom ash blowdown and flue gas desulfurization
system blowdown, if carried out in accordance with page 23 of
the attached conditions of certification, is supported by the
evidence adduced at the hearing. This variance request should
be granted for a period of two years.
In order to minimize damage to the proposed unit's
steam turbine, it is neevssary that TECO perform an operation kne
as steam blowing or steam venting. This operation nay result in
a violation of the noise level standards of the Hillsborough
County Environmental Protection Commission. The operation occur:-
only intermittently over a thirty (30) day period prior to the
initial startup of Big Bend Vnit No. 4. Provided that TECO agre.
to engage in a prior public notification program to notify resi-
dents in the area of the steam bloving operation, TECO should
4-50
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be granted a variance from the Commission's noise level stan-
dards (Rule 1-10.04A) for a period not to exceed thirty (30)
days from the commencement of the steam blowing operations.
There being no opposition to the variance request
from the surface water quality standards of the Hillsborough
County Environmental Protection Commission, and the request
being otherwise supported by the evidence adduced by the appli-
cant (with the exception of the lead parameter), this variance
request relating to general, chromium, iron and arsenic standards
should be granted for the life of the certification. The
requested variance from the lead standard should be denied since
the evidence failed to demonstrate that variance relief is
necessar: for that parameter.
RECOMMENDATION
Based upon the entire record of this proceeding and
the above findings of fact and conclusions of law,
XT IS RECOMMENDED THAT:
(1) Tampa Electric Company be granted certification
pursuant to Chapter 403, Part II, Florida Statutes, for the
location, construction and operation of Big Bend Unit No. 4,
the associated facilities and the directly associated transmissi
line, as proposed in the amended application and evidence in the
record;
(2) The certification be subject to the conditions
of certification attached to this Recommended order as Appendix
(3) The variance request from the Department of
environmental Regulation's surface water quality standards be
granted in accordance with the conditions o'5 certification whicr
are attached hereto;
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(4) The variance request from Hillsborough County
Environmental Protection Commission Pule 1-10.04A governing
noise requirements be granted for a period not to e/.ceed
thirty (30) cays from the commencement of steam blowing operations,
conditioned upon Tampa Electric Company's agreement to notify
the affected members of the public prior to tne steam blowing
operation;
Environmental Protection Commission surface water quality standards
contained in Rules 1-5.04, 2. (general), 1-3.04, 2.n (chromium),
1-5.04, 2.q (iron), and 1-5.04, 2.r (arsenic) be granted for the
life of the certification for Big Bend Unit No. 4: and
niwironmontal Protection Conunis:.ion surface water quality standard,
pertaining to lead, Rule 1-5.04, 2.p., be denied.
(5) The variance request from Hillsborough County
(6) The variance request from Hillsborough County
Respectfully submitted
July, 1981, in Tallahassee, Florida.
Hearing officer
Oivision of Administrative Hearings
The Oakland Building
2009 Apalachoe Parkway
Tallahassee, Florida 32301
(904) 488-9675
Filed with the Cler< of the Divisicr
of Administrative Hearings this
day of July, 1961, in Tallahassee,
Florida.
Copies furnished:
S<3« attached page
4-52
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Copies furnished:
Lawrence N. Curtin
and Robert P. Murray
Holland and Knight
Post Office Drawer BW
Lakeland, Florida 33802
Louis F. Hubener
Assistant General Counsel
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
Thomas E. Cdne, Jr.
Blair, and Cone, P.A.
202 Madison Street
Post Office Box 399
Tampa, Florida 33601
C. Laurence Keesey
Department of Veteran and
Conmunity Affairs
Room 204, Carlton Building
Tallahassee, Florida 32301
Arthur C. Canaday
General Counsel
Public Service Commission
101 Cast Gaines Street
Tallahassee, Florida 32301
Prentice C. Pruitt
Public Service Commission
101 Cast Gaines Street
Tallahassee, Florida 32301
Hamilton S. Oven, Jr.
Administrator, Power Plant Siting
Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, Florida 32301
4-53
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APPEND IX 1
Conditions of Certification
-54
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VI. Operation Safeguards 16
VII. Screening 16
VIII. Potable Hater Supply Systt.). 17
IX. Transformer and Electric Switching Sear ]7
X. Toxic, Deleterious, or Hazardous Materials 17
XI. Construction in Waters at' the State 17
A. Intake and Discharge 17
B. Relocation of Jacuson Branch 18
C. Newman Branch 18
XII. FGD/Gypsum Landfill 19
XIII. Transmission Lines 19
XIV. Change in Discharge 19
XV. Noncompliance Notification 19
XVI. Facil 1 ties Operation 20
XVII. Adverse Impact 20
XVIII. Right of Entry 20
XIX. Revocation or Suspension 20
XX. Civil and Criminal Liability 20
XXI. Property Riyhts 21
XXII. Severability 21
XXIII. Definitions
XXIV. Review of Site Certitic.it.wn 21
XXV. Ilodifi>.ation of Conditions 22
XXVI. Flood Control Protection 22
XXVII. Effect or" Certification 22
XXVIII. Fine '-'ash Screens 22
XXIX. Noise 22
\X>.. Variances 23
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State of Florida Depart-ent of Lnvw-oniiifi:jI ".ctjulatic.
Tarpa Electric Company
3ig Se'id Unit 4
PA 79-12
CONDITIONS OF CERTiriCATICN iXc*1
I. Air
Tne construction and operation of 3ig Bend Unit 4 at the Tair.pa
steam electric power plant site snail t>e in accordance with ill
applicable provisions of Chapters 17-2, 17-4, 17-5 and 17-7, Florida
Administrative Code. .In addition to the foregoing, the permittee
shall comply with the following conditions of certification:
A. Emission Limitations
1. 3ased on a maximum heat input of 4.330 mil Hen BTU per
hour, stacn'emissions from Big Bend Unit 4 shall not
exceed the following when burning coal:
a. SOg - 1.2 lb. per million BTU heat input, ~ax1rcum
two hour average. 0.:;h Ib/MMBtu on a 30-day roiling
average.
b. N0X - 0.60 lb. per million BTU heat input.
c. Particulates - 0.03 lb. per mil lion CTU heat input.
d. Visible emissions - *0 (6-min'jte averageexcept
ono 6-minijte pet io'i imc hour of no; "/ire than 27
opacity.
2. The height of the toiler exnaust stack for Unit 4 shall
not be less than 4go ft. above grade.
.>. r.irlkuljlc emissions t ro.:« Int.- *.o
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ratio and flow rate. The department may, upon review of
these data, disapprove the use of such device if the
Department determines the selected control device to be
inadequate to meet the ei..limits specified in 3(a)
above. Such disapproval siiull be issued within 30 days
of receipt of the is.l r ti r u 1te
fiiiiisions during construction, such as coating of roads
and construction sites used by contractors, will be taken
by the permittee.
10. Coal should not be burned in the unit uniess both e".ectro'
static precipitator and limestone scr.ibbf jes operating
properly•
11. Coal burned in ti e .mil snoula b<" v.asn.ei '..<:roi"e it
transported to the plant sTtc.
Air Moni toring Program
1. The permittee shall install aria operate contiguously
monitoring devices for the Unit 4 boiler exhausts for
sulfur dioxide, nitrogen dioxide, oxygen and opacity.
The monitoring devices shall meet the applicable require-
ments of Section 17-2.08, FAC, and 40 CFR 60.47a. The
opacity monitor may be placed in the duct work between
tne electrostatic precipitator and tne FQD scrubber.
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2. The permi i.tee or- iij IJsuorouyh county oh.iil operate trie
two ambient monitoring devices "for sulfur dioxide in ac-
cordance with EPA reference methods in 40 CFR, Part 53,
and two ansbient monitoring devices for suspended partic-
ulates. The monitoring devices shall be specifically
located at a location approved by the Department. The
frequency of operation shall be every six days commencing
as specified by the Department.
3. The permittee shall maintain a daily log of the
amounts and types of fuels used and copies of fuel analyses
containing Information on sulfur content, ash content and
heating values.
4. The permittee shall provide sampling ports into the
stack and shall provide access to the sampling ports, in
accordance with DER publication. Standard Sampling
Techniques and-Methods of Analysis" for the Determination
of A1r Pollutants "from Point Source. July. 1975.
5. The ambient i«nitoring pngram ;nay be reviewea by
tho Department and the remittee annually !>eyinning two
years after start-up of Unit. 4.
6. Prior to operation of the source, the permittee
shall submit to the Department a.standardized plan or
procedure that will allow the permittee to monitor emission
control equipment efficiency and enable the permittee to
return malfunctioning equipment to proper operation as
expeditiously as possible.
C. Stack Testing:
1. Within 60 calendar days after achieving the maximum
capacity at which each unit will be operated, but no
later than 180 operating days after initial start-up, the
permittee shall conduct performance tests for particulates
SO?. NO, and visible emissions during normal operations
near 4,530 MMBtu/hr heat input and furnish the Department
a written report of the results of such performance tests
within 30 days. The performance tests will be conducted
in accordance with the provisions of 40 CFP. 50.46a, 4Sa.
and 49a.
Z. Performance tests shall be conducted and data reduced
in accordance with methods and procedures in accordance
with OER's Standard Sampling Techniques and Methods of
Ana 1 vsis for Determina'tion" on A'ir Pollutants" f ronf "Point
SourcesI July,~TC7T: ""
4-58
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AIX SAMPLING STATIONS
HILLSBOROUGH COUNTY, FLORIDA
1979
I igure !
4-59
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3. Performance Lc.lr. ^h-i IS :>e i.un'Juc LcJ urnler such
conditions as the Department shall specify based on
representative performance ot the facility. The permittee
shall make available to the iiepartnont such records as
uuiy be necessary to Jeu>r:iiw the condition*. of the
performance tests.
4. The permittee shall ^ruvide 30 lays prior notice of
the performance tests to arford the Department the oppor-
tunity to have an observer present.
5. Stack tests ror particulates and shall be
performed annually tn accordance with conditions C. 2, 3,
and 4 above.
Reporting
1. For Unit 4, stack monitoring, 'uel usage and fuel
analysis data shall be reported to the Department's
Southwest District Office on a quarterly basis conrienc-
Ing with the start of commercial operation in accordance
with 40 CFR, Part 60, Section 60.7., and in accordance
with Section 17-2.OB, FAC.
2. Utilizing the SAROAU or other tor-mat approved in
writing by the Department, ambient air monitoring data
shall be reported to the Uureau of Air Quality Management
of the Department quarterly. Commencing on the date of
certification, such reports shall be due by the last day
of tne month following the quarterly reporting period.
3. 3egInning one month after certification, the permittee
shall submit to the Department a quarterly status report
briefly outlining progress made on engineering design and
purchase of major pieces of equipment (including control
equipment). All reports and information required to be
submitted under this conditicn shall oe submitted to the
Administrator of Power Plant Siting, Department of Environ-
mental Regulation, ?600 Blair Stone 3.o«d, Tallahassee,
Florida, 32301.
Water Discharges
Any uischjryes into any wui.o:' of the State during construc-
tion and operation of Dig Bend Unit 4 shall be in accordance witn
all applicable provisions of Chapter 17-3, Florida Administrative
Co*ie, and 40 CFR, 423, Effluent Guidelines and Standards for Steam
Electric Power Generating Point SourceTateoory. except as provided
herein. "Also, the permittee shall "comply with tne following con-
ditions of certification:
A. Pla.it Effluents and Receiving Sooy of water
For discharges made from tht power plant tne follcwirg con-
ditions shall apply:
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Receiving Body of Hater J_RliWj
The receiving body of water has been determined by
the Department to be those waters of the Tampa. Cay and*
any other waters affected which are considered to*be
waters of the State within the definition of Chapter 403,
Florida Statutes.
Point of Discharge (P.O.D.)
4 The point of discharge will be determined by the
Department to be where the effluent physically enters the
waters of the State.
'hernial Mixing Zone
The instantaneous zone of thermal mixing for the
cooling system shall not exceed an area of 4980 acres.
The temperature at the' point of discharge into the Tampa
Bay shall not be greater than 109 degrees F. The temper-
ature of the water at the edge of the mixing zone shall
not exceed the limitations of Paragraph 17-3.05{1)(J).
The permittee shall validate the size of this mixing zone
by submission of a verified or calibrated thermal dis-
persion model at least si a months prior to commencement
of ope ration. The Departiiicn t and TECO shall agree to a
program for selecting, verifying and utilizing an"
appropriate model.
Chemical Wastes
All discharges or low volume wastes (demineralizer
regeneration, floor drainage, lab drains and similar
wastes) shall comply with Chapter 17-3. If violations
"aTTFiapter 17-3 occur, corrective action shall be taken.
These wastewaters shall be discharged to an adequately
sized and constructed treatment facility. Preoperational
and operational metal cleaning wastes, low volume wastes,
boiler fireside wash, air preheater wash, and stack wasn
shall be disposed of in an adequately sized percolation
pond and spray irrigation facility.
Co 1 PJjle
Coal i'ile runoff sn.i".' Lie -i-ispose-i < ' -n the waste-
water trejtisient/soray irrujuion systei'i enj shall no: be
directly discharged to waters.
Chi ori ne
The concentration or tj-.j; resicjjl cnlcrir.e ;is-
ourjO'J t'rwr. U«i' ¦ i ial' nr.: s-.coe-; • 1 it the ?iju
4-61
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nor 0.01 mg/1 beyond an Instantaneous mixing zone of 6.1
acres. The condensers for Unit 4 shall not be chlo-
rinated more than two hours per day and shall not be
chlorinated simultaneously with any.other unit.
". £H
The pH of the combined discharges shall be such that
the pH be within the range of 6.0 to 3.5.
3. PolYChlorinated Bipnenvl Compounds
There shall be no net discharge of polychlorinated
biphenyl compounds.
9. FGD Chloride Bleedstream
The bleedstream from the FGD system shall be treated
to control pH, turbidity, solids and toxic metals prior
to discharge into the cooling water system. The following
effluent limitations will apply:
affluent Daily Maximum Maximum 30-Day
Oaily Average
TSS 100 mg/1 30 mg/1
Oil and Grease 20 mg/1 15 mg/1
pH 6-9 6-9
The design plans and specifications of the treatment
system shall be submitted to the Department for review
ond approval prior to construction.
10. Boiler and Bottom Ash Sluice System Blowdown
Slowdown from the boiler and from the bottom ash
sluice system shall be treated as appropriate prior to
discharge to the cooling water system. The following
effluent limitations shall apply:
Effluent Oaily Maximum Maximum 30-Day
Oaily Average
TSS 100 mg/1 30 mg/1
Oil and Grease 20 mg/1 15 mg/1
pH 6-9
TECO shall provide the dimensions of the bottom ash
system settling pond and provide calculations demonstrating
that sufficient residence time will be provided to achieve
the above limitations.
4-62
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1 ]. Gv£S_u;n Storage Area',
There shall be mo direct discharje :f stoniwater
runoff to surface waters frc:r the sypsuif. storage area.
1Z. Storm 'ddter Runoff
During plant operation. necessary measures sna11 be
used to settle, filter". treat or absorb s jlt-containinq
or" po.llu tan t-laden storniwater runoff to limit the sus-
pended solids to 50 iiig? 1 or less at the POP during rain-
falV periods less th7n the 10-year. 24-hour rainfall, and
to prevent an increase in"turbiditv of more than 50 '
Jackson Turbidity Units "b'ove background in waters of the
* id 150 meters Trom the POP at Station E 4500
Control measures shall- consist at the minimum of
Tpters. sediment traps, barriers, berms or vegetative
planting. Exposed or disturbed soil shall be protected
as soon as possible to minimize silt - and sediment-laoen
runoff. The PH shal1 te kept within the ranee of 6.0 to
8'. 5 at the P06T
13. Percolation Pond Overflow
There shall be no discharge from the wastewater
trsacinent system percolation pond except during emergency
conditions caused by severe w_eatner. *ny cischarqe Trcm
the existinft "overflow shaTi be repd"trted To the
flepartinent _the_ Jtivi: oiime'i\ itYTVn~t"gotT^'n""Agency" A11
dlschafes froii! this evert]ow sy'ste.n Ihal 1 b*i fnonitf"ec
for pH, TsT. oil anc graise. ar,d~th~e "letaYs fisted"'
in con_di_tjon 1_I_,_ H.1 ; r.hc Mow and d"uration of'"flow
sh'al'l "be es'tiiiia'fec.
Witej_ ftjn i.tori n<3_ Programs
'¦'ne permitteo ihflll .-unitcr jr.o roporf *.:s ch* f!e;,ar"j".enf.
tru li'jt'-'d parameters on Kit. is specifics herein. Trie
:>eThods anJ procedures utilueu shall receive* written approval
by tne Jepartrient. The :i»nitaring progrir.i may be reviewed
ann-ally by the Department, ma
-------
Parameter
Location
Sample Type
Frequency
Flow, Cooling
Flow, Bottom Ash
Flow, Boiler Slow-
down
rlow, FGO Bleed
pn
Temperature
TSS
Chlorine, Total
Residual
Oil and Grease
Metals
Arsenic
Cadmi uiu
Iron
lead
Mercury
Selenium
Zinc
Copper
Chromium
Nickel
Intake
Prior to CWS
Prior to CWS
Prior to CWS
CWS and prior 'to
CWS on FGD Bleed
Boiler & Bottom
Ash Blowdown
CWS Outfall
Bottom ash Clow-
down, FGO Bleed,
J Boiler Slowdown
Outfall
Boiler 21owOown
3ottom Ash [Slow-
down and FiiO
bleed
Intake. Outfel i
FGiJ Uleed Slreuiti
Bottom Ash Blow-
Jnwn s Boiler
Blowdown Prior
to discharge
to CWS
Pump Log
Recorder
Daily Loo
Recorder
Grab
Recorder
Grab
Multiple Grao
Crab
Two-Grab
composite. not
less than
'tours beLween
samples
Conti nuous
Continuous
Daily
Continuous
Two per Week
Continuous
Two per Week
Two :er Month
Weekly
Two per Konth
Two iJ»M* Month
for the first
year, then monthly
thereafter
Biological Monitaring
Thermal Studies
bji'ipliny shall be done on a u i-'•n.r.iy basis ton-enciny ere «onth
after certification end shall continue for a period of one year after
'Jr.it A is on-iine. Such sampling shall consist of a baseline survey and
an intensive survey. Sampling metho-Jolngy shall be the same as that in
the 1579 aquatic biology studies. !lovi.itloir, from that -;:ethodoloqy
shall be approved by the DER.
All raw data shall be available upon request by 'Jr.?.. At trie er.a of
t'-ie first year of pcst-cperational stMiiy. the Department shall review all
of trie data in the form of an annual :e;;ort and shall leteraine i'
*'.ViS - i ¦ Iitsy Water iystei1;
Revise-: 6,2/31
4-64
-------
mitigative action must be taken by TECO .ind shfill determine if the
impacts of the thermal discharge are in compliance with the requirements
of Section 17->. 05(1 )(f) and if the thermal mixing zone yranted by
londition II.A.3 is appropriate, if the d-:ta are sufficient to convince
the Department that severe thermal * free is nave ;een confine': to ar.
acceptably lvnitcJ uroa, the nonilo'¦ 11.-j i.¦ ,i;ii;hnl be ter'ninat^d. It
not. the studies snail be continjeu ».nii' ci!=.e as the tt-ermol
inpact can be thoroughly evaluated.
(1) Gosel ine Sjjjrvey
In Older to put the 1979 bfnti.v. :i,ly in proper ecnlogic.il
perspective regarding the regular cyclical biotic fluctuations
which are known to occur in Tji:pj liuy, the following program
shall be implemented:
i. Benthic iiiacroinvertebrate sampling shall be carried out
on a bi-monthly basis one month after the tiire of enact-
ment of certification until a period of 12 ironths prior
to commencement of operation of Unit 4. Five stations
corresponding to stations 5, 6, £, 11, and 12 of the
1979 Benthic Ecology Study* shall be sampled according to
the methods outlined in the TECo benthic reoort. Deviations
from that methodology shall be approved by the OER.
ii. Water quality parameters shall be monitored during the
benthic sampling prfjram on a bi-monthly basis at eacn of
the above stations. P.iraiwters to be examined shall in-
clude salinity, dissolved oxyoen, turbidity, and water
temperature (top .ir.d bottom).
in. «\ mi siwi I bi_- < hi icu uut ji w.h oi these
stations on a bi-.!«ntnly na*. iv. corresponding to *he benthic
iny according to ;.»u: inetlwls outlined in the 1979
Centhic StoJy. M seilimuMt s.iiiiples show little bi-
wonthly variability. TcCo :nay request a less rigorous
sampling frequency.
In order to adequately ¦jssess ".no inerwa' impact of uiy Cend
Unit j in conjunction with tiie combined plune di rjnarge frcr
Onits 1,2, and 2, the fo'lowing biological moni*oring
program shall be in.p1eir.ented one yar before and snail con-
tinue for ore year after caninienLei-iinC of operation of Ur.it 4.
A proposal for these intensive studies snail be prepared by
tl-,e apolicant and shall be subritted to DER for approval at
least 18 months prior to coxnercial operation of Unit 4. Such
a proposal shall reflect the methodologies employed during
the U79 study so that .both data sets can be comsared for
evaluation of thermal i-Tat*. from Unit i.
'Study -if Thermal Effects or. ra-'ii,. v.i!.a::»mi -Jo? vf 5i-j u«'-...
lay (Florida)", July 19o0. 7L10
:.e'. isou 6/2/S1
4-65
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i. The applicant, shall collect bi-monthly oenthic, samples.
The stations to be chosen for the Benthic sampling program
shall be taken the 1979 Benthic Ecology Study plus
three additional station*. These three stations shjll be
located on j tr'insect amnir.u into the bay '"cm station
parallel iny stations 5, 6, and 7 of the 1979 study.
Water quality parameter^ and sediment samples shall be
collected and analyzed as in the baseline survey.
ii. Stations 1 and 2 shall he deleted from the proposed
studies.
iii. Trammel (or gill net) *een
return system.
^ i.uion .i: Lcmii»ii ihi- : r-i.
station j: At the uts«.K.nje pu'nt in tv 'Vj-mls.-:
Return f.0nsl;oac).
Staticns 1 Jin! Z j'-i s:a ii-niltaneously " o •_iti::;a;e ".he
total nun~.bei* of c*r-j:nirted by T'.wo at 's-»t
twelve mr.ihs prior -.5 the cd.!:•>(!t oormerf lal operation '.Tit i.
Wit.jl- U'jO
• V-iS. o* Vldtdr
I
TECO shall use the lowest quality water wnicn it has the
ability to use. Tc the extent that a dependable supply of
non-potaole water can be provided, TECO shall use ti-e non-
potable water 1n lieu of the potable water fro.r. the public
Revised 6/2/81
4-66
-------
water supply system ot Hi 1>L
-------
testing program shall be iubmitteu to the uepartment and
the Director, Regulatory Division of SViFWMD, and approved
prior to connnem-cwent of the investigation. The investigation
should include out need not be limited to the following:
4. The geology encountered wnile aril ling the
well, with emphasis placed on the depth, thick-
ness and Hydraulic characteristics of for-
mations encountered.
0. The aquifer svstems that are encountered, along
with the -lisc.ussion on water quality and avail-
:iB 11ty.
c. I'urfon-once ur a t'jst, description of
aquifer characteristics and evaluation pro-
cedure.
1. ¦': iu' ' j'.-i.^/sical
¦: itir..-. i- ii • t .. i rncharye >•'-i i 11 ii..o t«:
jC-urco.
'-'pun completion i,; ti.e iiivesti^uticns, "ECO sn.ill submit
•l report on the feasibility cf utilizing brackish groundwater
for cooling tower .nake-jp, anu at that tine the SWFWMD may
authorize withdrawals. If SWFWMD should authorize withdrawals
of brackish water, TtCO shall -.ubmit ;:»ntnly Dumpage reports
and chlorides, sulfate and TDi ma lysis on the production well
to the SWFWMD.
Emergency Shortages
in the event an emergency water shortage shoulc be declared
pursuant to Section 373.175 or 373.246. F.S., by Southwest
Florida Water Management Oistrict for an area including
Hillsborough County, the Department pursuant to Section 403.516,
r.S., may alter, modify, or declare to be inactive all cr
parts of Condition IIl.A.-E. An authorized SWFKMO -eoresenzative
.it any reasonable time may enter the procerty to inspect the
facilIties.
Monitoring ano '.eeortirj
Tamp, Electric I nri.paiiy s-'.i i ! i i:;p i c- »v.' t.ni "/i icwin':
>ji'uiindw,iter noni i.omiij pi¦'¦ c i:
4-68
-------
1. The >jround',vuLev levels \hall be licnitored at wells as
approved by GER and the Southwest Water Management
District. Chemical analyses shall be made cn samples
from all monitored wells identified in tnis Condition.
The location, frequency, w.itfr levels And selected
chemical analyses shall ue as given in Condition
«!»- The groundwater wr.itvmy progr»:r. shall te Implemented
at least one ye.ir prior -o vt'eration of iii'j Send Unit ¦*.
The chenic*! mal./ses snail te in jeeord with the latest
edition 01 standard '•'i.ahoi.l--. :or me Analysis o_f_ Water
and Wastewater. The .idcn r,r.cli be submitted within" 20
days or"co'fTec tion/anjlys i: to tne Southwest Florida
Mater Management District and to the DER Power Plant
Siting Section.
3. After consultation witn thy ULR and SWFWMO, TECO shall
install a monitoring well sysLen, as generally shown on
Figure 3, to monitor ijroundwater quality in the top 40
feet of the surficial auuifer. One well shall be installed
to a depth greater than 40 feet but less than 100 to
monitor vertical dispersion or groundwater contaminants.
Monitoring well locations and designs shall be submitted
to the Department and SWFWMO for review. Approval or
disapproval of the locations and design shall be granted
within 60 days. The water samples collected frora each of
the monitor welis iha'l be collected immediately after
removal by pumpimi o* ;i quantity of water equal 10 two
car.ini volumes. Tlv w.ir^r quality analysts shall b*
purHiiiiioJ <11011 Lilly 'Jin iii'i t.hc y.'dr prior to conr'titial
operation and for cwo yens nfter operation and quarterly
thereafter. Results snail be submitted to the Department
and the SWF*MD by the fifteenth (15th) day of the month
following the issonrh duriny which such aiulyse'; were
performed. Testinq for r.he following constituents is
requi red:
4. Ar'-jr the second year cf :tcr.i taring and periodically
thereafter, the Deyartnier:t ana t.h.e permittee shall review
the results of the txnitsring prograc: and determine the
necessity for nidifying or continuing the proyr^R.
III.0.3.
i jr
-------
If
4-70
-------
E. Leachate
1. Zone of Discharge
Leachate from the FGD/gypsun landfill, coal storage
pile, bottom ash pond, wastewater treatment ponds, ash
disposal cells, -md spiay irrigation field shall not
^contaminate waters of the State (including both surface
and groundwaters) in excess of the limitations of
Chapter 17-3. FAC., beyona the bO'jndary_ of the site.
2. Corrective Action
When the jro-ind'Adter r:jni*.criny system snews a
violation of the grouniwater water quality stardards of
Chapter 17-3, FAC., the appropriate ponds, FGD landfill,
or coal pile shall be sealed, relocated or closed, or the
operation of the affected facility shall be altered in
such a manner as to assure the Department tnat no violation
of the groundwater standards will occur beyond the boundary
of the site.
IV. Control Measures During Construct ion
A. S torn water Runoff
Ouring construction, necessary measures shall be used to
settle, filter, treat or absorb silt-containing or polljtant-laden
stonitwater runoff to limit the suspended solids to 50 mg/1 or
less at the POO during rainfall periods less than the 10-year.
24-hour rainfall, and to prevent an increase in turbidity of
more than 50 Jackson Turbidity Units above background in
waters of the State beyond 150 frr»m .fh» ?nn
Control measures shall consist at the minimum of filters,
sediment traps, barriers, berms or vegetative planting.
Exposed or disturbed soil shall be protected as scjn as possible
tc minimize silt- and sediment¦laden runoff. The pH shall be
kt-pt within the ranje of s.r. to '.5 at the ?0t.
8. Sanitary Wastes
Disposal c:' sa*nr-i:\, cetistr r.'i'.- :t:let
facilities snail be in ac.oi -i.mte w i :n appl '"u-jjiatioiis
of the Department and ji.-piui ¦ i.ttd lucal nealtn . The
sewage treatment piant sha^l be operatea in stcoriance with
Chapters 17-3, 17-6, 17-16, aiij 17-15, "AC.
C. environmental Control Pro<;rai:i
An environniental c-trol j-royrai;. shal 1 be cstuulishtd
under the supervision of a qualified person to assure that ail
construction activities conform tc good environment.*'. practices
and the applicable conditions of certification.
Revised 6/2/31
4-71
-------
The permittee shall notify the Department by telephone if
unexpected narmful effects or evidence of 1 rreversible environmental
damage are detected during construction, shall inmesiately
report in writing to the Cepurfhent and shall within two weeKs
provide an analyses of trie problem and a plan to eliminate or
sujiiificantly reduce the h.ir:u 1 effects sr damage and a plan
to prevent reoccurrence.'
D• Discharge of Construction Jewaterii»q Effluent
Construction dewatering effluent shall be treated as
appropriate to limit suspended solids to no more than 50 mg/1.
The discharge of construction dewatering liquids shall not
cause turbidity in excess of 50 Jackson Turbidity Units
above ambient beyond a 20 r.iecer radius from the point of dis-
charge. Weekly grab samples will be collected and analyzed
for suspended solids.
Sol id Hastes
Sol iJ wastes resulting •••;. . ¦.str.^.t'-jn cceration sha'.'. be
aisposec of in accordar.ce wi-.n v.i. .v. sb.e reg-i s'.ions s* Chapter
17-7, FAC. The p?'Ti1t t.ee sn.'.l; s-.r.. it j ^'or e3;rv/al
outlining trte "ethoas to se u»e; ir. hanaiin^ and disposal of solid
wastes. Such proa ram shall inoieate at the least methods for
erosion control, covering, vetinn and quality control.
Open burning in connection wir.n land clearing snail be in
accordance with Chapter 17-5, !'AC. No additional permits snail be
required, but the Oivision ol rurtstry *»!^rtijn of the Florid D*p«irtrent of
Coiiwierce will also be complied with.
. Screening
The jwinittee sholl provicr m. ; ¦.•eniny of Uie .He tnrjuyh i.n?
use of aesthetically acceptaole structures, v^etited earthen walls
and/or existing or planted vegetation in accordance with Hi! '.sborough
County ordinances.
4-72
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VIII. Potable Water Supply System
The potable water supply_5yste!ii snail be designed and operated
in conformance with Chapter 17-22, FAC. Information asrequired in
17-22.108 shall be submitted to the Department prior to construction
and operation. The operator of the potable water supply system
shall be certified in accordance with Chapter 17-16, FAC.
IX. Transformer and Electric Switching Gear
The fotfhdatlons for transformers, capacitors, and switching
gear necessary to connect Sig Send Unit 4 to the existing distribution
system shall be constructed of an impervious material and shall be
constructed in such a manner as to allow complete collection and
recovery of any spills or leakage of oily, toxic, or hazardous
substances.
X. Toxic, Deleterious, or Hazardous Materials
The spill of any toxic, deleterious, or nazaraous materials
shall be reported in the manner specified by Condition XV.
XI. Construction in Waters ot__the S'.ate
A. Intake and Discharge
1. No construction jr so/erei'jntj 3ufc..ieic«d lands snail
cOMKence wii.houi oi.T,iir.i:nj u.jse or tit;e from the
OeparWien-. '*• ur <1 Resources.
Constru. .it.'; i.:; -li ¦,<; structures
sheulJ Ic done :i. j.-wie- i-j .rin'nrize turt>Mit/.
Turbidit/ srrotms - i;-¦ u 1 r! iii; jse'i ro prevent turbioity
in excess o: 50 JT:,''. jocve oackor-juiid ^evond 150
meters trcm we Iretlijing, pile driving, or construction
site.
3. The construction methodology for the intake
structure and screens shall be provided to the
Department's Southwest District Office for review
prior to construction.
4. All spoil shall be piped hydraulica!"./ or trucked to
an upland disposal site of sufficient capacity to
retain all material.
5. Effective stabilization of submerged bottom sediments
at the Coding Water System discr.arge should be
achieved and maintained during the period of operation
by the placenent of concrete, riprao or other suitable
material .
4-73
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6. Relocation or Jackson Branch
1. An equivalent. si|UJi'e tuuUyr of manyr-oves will be
replanted in the new irvek cut.
2. The new cretk will li.ivu 6:1 :nle slope* M" M3L
to -1' MSL.
3. Juncus sp. are to be planted at th'ee foot intervals
for the entire length of the relocated se^rent of
the branch according to sound management practices.
4. The 90° turn In the creek should be stabilized by
riprap as well as the planting of a higher concentration
of Juncus sp. on the outside of the turn.
5. The relocated cut 1s to be excavated and stabilized
behind an upstream plug before being connected to
the existing"creek; conversely, the existing branch
shall not be taken off line until the new cut is
stabilized and JTUs are less than 25 in the new
channel.
6. Permittee should submit to the Southwest District
Office a replanting proposal at least 60 days prior
to commencement of construction, including species,
methods and placement details.
7. Permittee will monitor the outfall of Jackson Srancn
twice daily during construction for turbidity in
JTUs and report these results weekly to the Southwe-.t
Olstrict Office.
C. Newman Branch
1. In the construction of the FGD/gypsum disposal areas,
TECO shall not alter the ditch along the east sice of
3each Road, as that di'ch is tidallv connected to Newman
Branch.
2. To mitigate against tne loss of the gross por.d in tne
area designated as I'liusc- I or the FCD/gypsum disposJ
area, TECO shall reconstruct tne northernmost east-west
drainaye canal. The sioe slopes of this drainage canal
on the TECO property snail be reduced to at least
6:1 (horizontal to vertical) and planted with Juncus
effusus. Such reconstruction shall be done in a
manner to prevent violation of Section 17-3.121, F.A.C,
Mater Quality Criteria. Plans for canal reconstruction
shall be submitted to the Department for approval
sixty days prior to reconstruction of the canal.
4-74
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XII. FGP/Gvpsuin landfill
The proposed fGO/gypsum iai.jtill area shall mcni'tored and
studied pursuant to a detailed jroundwatei testing and i-cni coring
program as defined in Condition III D.
The results of the program will be used by the Department in
determining whether TECO has affirmatively demonstrated that Florida
Water Quality Criteria (Chapter 17-?, f.A.C) will not be violated.
If the Department determines that TECo has failed to affirmatively
demonstrate that Florida Water duality Criteria (Chapter 17-3,
F.A.C) will not be violated, TCCn shall within 90 days of such
determination present to the Department a plan of correction (which
may include, if appropriate, an impermeable liner; for review and
approval by the Department and for timely implementation by TECO.
Construction of perimetershall be in conformance with
the provisions of Chapter 17-9, FA», regarding earthen dams.
o 11 utur:t. nut iJenIi I ied in 'Jit* ippl ication yr- an/ discharge
''ore frequent than, or at. a lew! in o.-.cos' of, that iu'.l.oriz-vl
herein shall constitute a violation of the certification. Any
anticipated facility expansions, nroducticn increases, or process
modification which will result in new, different or increased
discharges or expansion in steam jonerating capacity will require a
sul'i'iission ol' a new or i.uppKvwni.jl |jl iiiUiur putyiarr. Lj Cnaptar
403, Florida Statutes.
•:v. Noncompliance Npti ricatio.i
i', for any reejou, rne ,»*• n '.tee Joes not coi ; >/ .*i tn or wi. I
:->c unaolo to conv'., wiut any 1111 a ion »!«.••.i f ic-j i*. t! is ki- : i f icaticn,
the permittee shall notify t^e Manager oi OER's icutrv.-/»sr. j'strict
Office by telephone -luring the working day in which permittee
becomes aware of said noncompliance and shall confirm tris situation
in writing witnin seventy-two (72> hours supplying the fclicwing
information:
a. A description and cause gr noncampii«nte; and
4-75
-------
b. the period of noncompliance, including exact dates and times;
or, if not corrected, the anticipated time the noncompliance
is expected to continue, and steps being taken to reduce,
eliminate and prevent recurrence of Uie nonco:-p1ying event.
XVI. Facilities Operation
The permittee shall at all times maintain in good working
order and operate as efficiently as possible all treatment or
control facilities or systems installed or used by the permittee to
achieve compliance with the terms and conditions of this certification.
Such systems are not to be bypassed without prior Department approval.
The one exception is that durimj periods when light oil is used for
ignition, the FGD system may be bypassed.
XVII. Adverse Impact
The permittee shall take ail reasonable steps to minimize any
adverse impact resulting from noncoiiiyliance with any limitation
specified in this oertificatioi«, inclu-iny, but <'.ot limited *.o,
such accelerated or adciticnal ..onuoring as ncc^siary to cetennine
the nature and impact of the nor.coi'"lying event.
X < i! I. Sii)ht_ of Entry
The permittee shall allow lite Secretary of th* Florida Department
of Environmental Regulation and/or authorizea respresentatives,
upon the presentation of credentials:
a. To e .ter upon the permittee's premises wnere an effluent
source is located ov in which records are required to be
kept under the terms and conditions of this permit; and
b. to have access to and copy all records required to be
kept under the conditions of this certification; and
c. to inspect and test any monitoring equipment or monitoring
method required in this certification and to sample any
discharge or pollutants; ino
d. to assess any damage to :.he envi roniiipnt or violation of
ambient standards.
X1X. Revocation or Suspension
This certification .idy l>t; or to
section J03.5I2, Florida Statutes, ar 'or violations cf any Condition
of Certification.
(. Civil and.Crin»ina.l_Ljab 11 ic<
li.is certification joes *** T c.-vi*
4-76
-------
oi* criminal responsibility or liability for noncompliance with any
conditions of this certification, applicable rules or regulations
of the Department, or Chapter 403, Florida Statutes, or regulations
thereunder.
Subject to Section 40J.S-II. Ploiiuj Statutes, this certification
shall not preclude the institution of any legal action or reiieve
the permittee from any responsibilities or penalties established
pursuant to. any other applicable State Statutes or regulations.
XXI. Property Rights
The issuance of this certification does not convey any property
rights in either real or personal property, tangible or intangiole,
nor any exclusive privileges, nor ooes it authorize any injury to
public or private property or any invasion of personal rights, nor
any infringement of Federal, State or local laws or regulations.
The applicant will obtain title, leaso or right of use to any
sovereign submerged lands occupied by the plant, transmission line
structures, or appui tenant facilities from the State of Florida.
XXII. Severability
The provisions of this certification are severable, and, if
any provision of this certification or the application of any
provision of this certification to any circumstances is held invalid,
the application of such provision to other circumstances and the
remainder of the certification shall not be affected thereby.,
XXIII. Definitions
The meaning of terms used herein snail be governed by the
definitions contained in Chapter 403, Florida Statutes, and any
regulation adopted pursuant thereto. In the event of any aispute
over the meaning of a term used in these general or special conditions
which is not defined in such statutes or regulations, such dispute
shall be resolved by reference to the most relevant definitions
contained in any other state or Vetera I statute or regulation or,
in the alternative, by the use of '.ne •¦onmcnly ai/:°otec ire an i ng as
determined by the Department.
v \! V. Rev jew of Site Cert; r i c.-1* o«>
The certification sna'i i „i: ; iiu i .:i ess • i: -.-c. c-vokeu «;•
suspended pursuant to law. At least tvery rive /pars from the .sate
of issuance of this certification ui .my nation.¦! ^oli.jtant Discharge
11 imination System Permit issued pursuant to the Water
Pollution Control Act Amendments of 1972 for the plant units, tne
Department shall review all. monitoring data that has been submitted
4-77
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to it during the proceeaing five-year period for the purpose of
determining the extent of the permittee's compliance with the
c. jitions of this certification of the environmental impact of
this facility. The Department shall submit the results of its
review and recommendations to the permittee. Such review will be
repeated at least every five years thereafter.
XXV. Modification of Conditions
The conditions of this certification may be modified in tne
following manner:
A. The Board hereby delegate. to the Secretary the authority
to :odify. after notice u: u t'pporunity for hearing, any
conditions pertaining u> assumptive jse of water, n,onitorin^,
sampling, groundwater, mixing zones, zones of discharge
or variances to water quality standards.
B. All other inodifications shall be made in accordance .;ith
Section 403.516, Floridu Statutes.
XXVI. Flood Control Protection
The plant and associated facilities shall be constructed in
such a manner as to comply with the hillsborough County flood
protection requirements.
XXVII. U'fecl of Certification
Certification and conditions of certification are predicated
upon design and per to nuance enter id indicated in the application.
Thus, conformance to those criteria, unless specifically amended,
modified, or as the Department and parties are otherwise notified,
is binding upon the applicant in the preparation, construction and
maintenance of the- certified project. In those instances where a
conflict occurs between the application's design criteria and the
conditions of certlficaiton, the conditions shall prevail.
XXVIII. Fine Mesh Screens
Fine mesh screens, similar to those tested arc aescribec by
TECO in the 316 Demonstration, snail be installed ;n tne intakes
of Units 3 and 4 with the appropriate sprays and screen wash sluice
return system to minimize entrapment. The screen .vasn sluice
return system shall discharge to the east end of -he canal north of
the intake canal or to a location acceptable to the Department
and EPA. TECO shall submit a plan to ..DEB-10.explore tn« posficilllx.
of re-entralnment of PRC—returned organism.
Ma. Noise
.the cts of ::oi;e prc£u>/.>c .ty st»:ar. blo*cut
vised 6. 2,'il
4-78
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of steam boiler tubes and by cor,struction of the Phase IV FGD
byproduct disposal area. "fECo shall conduct public awareness
campaigns prior-to such activi ties to forewarn the public of the
estimated time and duration of the noise.'
XXX. Variances
TECO is granted variances for discharges of boiler blowdown, FGD
system blowdown and bottom ash pond blowdown pursuant to Sections
403.201 and 403.511(2) F.S., for a period of two years after the start
of comnercial operation for the following parameters:
a. Arsenic - 17-3.061(2)(a)
b. Cadmium - 17-3.121(9)
c. Chromium- 17-3.061(2)(d)
d. Copper - 17-3.121(11)
e. Iron - 17-3.121(16)
f. Mercury - 17-3.121(18)
g. Nickel - 17-3.121(19)
h. Selenium - 17-3.121(26)
During the period that the variance ij in effect, T£C0 shall (1)
determine the concentrations of the above -letais as well a; lead, in the
three discharge streams; (2) operate the FGD blowdown treatment system
so as to minimize the metal content of the discharge from the system;
{3) explore the practicability of treating the boiler blowdown in the
FG0 treatment system when there is capacity in the system tq accomodate
that blowdown; and (4) submit reports of the above studies and analyses
after the first year and at least twenty irnmths after the start of
comnercial operation of Unit 4. Based upon data from existing Units 1,
2. ;nd 3 contained in the application, during the period of the
variance, the quality of the boiler blowdown shall not exceed the following:
Arsenic
O.Z
mg/1
Cadmium
0.005
mg/1
Chromium
0.065
mg/1
Copper
0.04
mg/1
Iron
0.001
ing/1
Lead
0.05
mg/1
Mercury
0.007
mg/1
Nickel
0.C96
mg/1
Selenium
0.032
mg/1
upon receipt of the aforementioned reports, th* Secretary shall
Jetermine whether ine variances should be renewed and may impose
appropriate conditions to minimize the discharges and their impacts.
4-79
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Chris H. Bentley
Director
ATTACHMENT 2
Bob Graham
Governor
Nevin G. Smith
Secretary of Administratic
STATi: OI; FLORIDA
Bepartment of gfoministration
Division of Administrative Hearings
Oakland Building, 2009 Apalachce Parkway
TALLAHASSEE
U\Q\
August 5, 1981
Honorable Victoria Tschinkel
Secretary, Department of
Environmental Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
Re: Tampa Electric Company vs.
Department of Environmental
Regulation - Case No. 81-1463
Dear Secretary Tschinkel:
Enclosed is my Recommended Order in the referenced
proceeding, along with Joint Exhibits 1 through 3 received into
evidence at the hearing.
Copies of this letter will serve to notify the
parties that my Recommended Order and the record have been
transmitted to you on this date. Pursuant to Section 120.57
(b)(8), Florida Statutes, the parties are advised that they are
allowed ten (10) days from the date of this Recommended Order
to file written exceptions thereto with the Department of
Environmental Regulation.
Please furnish the Division of Administrative Hearings
with a copy of the final order rendered in this proceeding so that
our files will be complete.
Sincerely,
DDT/sw
Enclosures
cc: Lawrence N. Curtin
Louis F. Hubener
Hamilton S. Oven
DIANE D. TREMOR
Hearing Officer
An Affirmative Action, Equal Opportunity Employer
4-80
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STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
TAMPA ELECTRIC COMPANY,
Petitioner,
vs.
DEPARTMENT OF ENVIRONMENTAL
REGULATION,
Respondent.
Case No. 81-1463
RECOMMENDED ORDER
Pursuant to notice, an administrative hearing was
held before Diane D. Tremor, Hearing Officer with the Division
of Administrative Hearings, on June 23, 1981, in the Hillsborough
County Courthouse, Tampa, Florida. The issue for determination
at the hearing was whether the Department of Environmental Regulation
should grant Tampa Electric Company's petition for a variance from
certain Florida water quality standards for the discharge from the
existing slag pond for Units 1, 2 and 3 of the Big Bend Generating
Station located in Hillsborough County, Florida. The parties
agreed upon all issues at or prior to the hearing and their Joint
Exhibits 1, 2 and 3 were received into evidence.
APPEARANCES
For Petitioner:
For Respondent:
Lawrence N. Curtin
Holland £ Knight
Post Office Drawer BW
Lakeland, Florida 33802
Louis F. Hubener
Assistant General Counsel
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
FINDINGS OF FACT
Upon consideration of the petition for a variance,
the recommendation of the Department of Environmental Regulation
4-81
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and the prehearing stipulation of the parties, the following
relevant facts are foundi
(1) Tampa Electric Company is the owner and
operator of the Big Bend Generating Station which presently con-
sists of three coal fired steam electric generating units (Units
1, 2 and 3) in Hillsborough County, Florida. The Big Bend
Generating Station is located on the eastern shore of Hillsborough
Bay, a Class III body of water. Discharges from the Big Bend
Station are subject to regulation by the Department of Environ-
mental Regulation.
(2) The discharge that is the subject of this
proceeding is from the slag pond currently serving Big Bend Units
1, 2 and 3. Tampa Electric Company originally requested variances
from the surface water quality standards contained in Rules 17-3.051
(minimum criteria), 17-3.061(2) (general prohibition), 17-3.061(2)(a)
(arsenic), 17-3.061(2)(d) (chromium), 17-3.061(2)(h) (lead),
17-3.121(9) (cadmium), 17-3.121(11) (copper), 17-3.121(16) (iron),
17-3.121(17)(lead), 17-3.121(18) (mercury), 17-3.121(19) (nickel),
and 17-3.121(26) (selenium) of the Florida Administrative Code for
the discharge from this existing slag pond. At the hearing, Tampa
Electric Company withdrew its request for variances from the pro-
visions of Rules 17-3.051 (minimum criteria), 17-3.061(2) (general
prohibition), and 17-3.061(2)(h) and 17-3.121(17) (lead).
(3) Data collected by Tampa Electric Company during
the period of 1970 through 1974, 1980 and 1981 demonstrate that
the quality of the ambient intake water in Hillsborough Bay con-
tains concentrations of arsenic, chromium, cadmium, copper, iron,
mercury, nickel, and selenium in amounts which periodically
exceed the applicable Florida water quality standards for that
water body as contained in Chapter 17-3, Florida Administrative Code.
4-82
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(4) Water quality data for the Big Bend Units 1,
- 2 and 3 slag pond discharge collected during the 1980-1981 study
demonstrate that there will be either minimal or no net increase,
or a reduction between the ambient intake and discharge for all
metals except iron and selenium. Upon mixing with the flow in
the discharge canal, water quality impacts due to these parameters
are expected to be minimal.
(5) Tfie Department of Environmental Regulation has
recommended granting a variance for the parameters cadmium, mercury
and nickel based upon the following!
(a) mercury concentrations decrease upon passing
through the slag pond;
(b) cadmium and nickel concentrations remain the
same passing through the slag pond; and, therefore,
(c) the slag pond system does not appear to con-
tribute to the existing water quality violations for cadmium,
mercury, or nickel.
(6) The Department of Environmental Regulation's
analysis of the other parameters indicates that the concentrations
of arsenic, chromium, iron and selenium increase in passing through
the slag pond system. This increase appears to be due to an increase
in suspended metals.
(7) Additional treatment of the discharge from the
slag pond would be necessary to meet water quality criteria in the
effluent for the parameters arsenic, chromium, iron and selenium.
Compliance would require further removal of these parameters
possibly by the use of a reverse osmosis treatment system. The
cost of treating the slag pond discharge pond stream to comply with
water quality standards by use of reverse osmosis would be approxi-
mately $28.2 million. The $28.2 million expenditure is not justified
or practicable in this case. The Department of Environmental Regulation
4-83
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agrees that this expenditure is not justified in this case
and has recommended a variance for these parameters as well.
(8) The damage or harm resulting or which may
result to Tampa Electric Company from compliance with the rules
from which the variance relief is sought would be the expendi-
ture of $28.2 million for an additional treatment system with no
significant resulting benefit to the environment. The failure
of the Department of Environmental Regulation to grant the
requested variance could result in Tampa Electric Company bain?
unable to operate this facility.
(9) The Department of Environmental Regulation
recommends a two-year variance from the surface water quality
standards contained in Rules 17-3.061(2)(a) (arsenic), 17-3.061(2)
(d) (chromium), 17-3.121(9) (cadmium), 17-3.121(11) (copper),
17-3.121(16) (iron), 17-3.121(18) (mercury), 17-3.121(19) (nickel),
and 17-3.121(26) (selenium) of the Florida Administrative Cod* for
the discharge from the slag pond serving existing Big Bend Station
Units 1, 2 and 3. The recommendation is conditioned upon Tampa
Electric Company's agreement to monitor the metal content of the
slag pond discharge, to evaluate alternative treatment systems
and to submit a report describing treatment systems evaluated,
including costs and feasibility, within eighteen (18) months of
the effective date of the variance relief. Tampa Electric Company
has agreed to the recommendation and conditions of the Department
of Environmental Regulation.
(10) Appropriate public notice of this proceeding -has
been given. At the conclusion of the hearing, the public was
given an opportunity to comment and present evidence on the
petition for variance. No public testimony was offered.
CONCLUSIONS OF LAW
Within its discretion, the Department of Environmental
Regulation may grant a variance from its rules relating to water
4-84
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quality for any of the following reasons:
(a) There is no practicable means known or
available for the adequate control of the
pollution involved.
(b) Compliance with the particular require-
ment or requirements from which a variance
is sought will necessitate the taking of mea-
sures which, because of their extent or cost,
must be spread over a considerable period of
time. A variance granted for this reason shall
prescribe a timetable for the taking of the
measures required.
(c) To relieve or prevent hardship of a kind
other than those provided for in paragraphs
(a) and (b). Variances and renewals thereof
granted under authority of this paragraph shall
each be limited to a period of 24 months except
that variances granted pursuant to part II may
extend for the life of the permit or certification.
S403.201, Fla. Stats.
Also see Rule 17-1.57, Florida Administrative Code.
In this proceeding, the record establishes that the
pond system does not contribute to existing water quality vio-
lations for cadium, mercury or nickel. Therefore, a variance
for these parameters should be granted.
Due to an increase in suspended metals, the parameters
of arsenic, chromium, iron and selenium increase when passing
through the slag pond system. While the resulting water quality
violations might be cured by the use of a reverse osmosis treat-
ment system, the cost of so treating the slag pond discharge
stream - $28.2 million - is not justified or practicable and
would result in no significant benefit to the environment. Other
less costly treatment or filtration systems to remove suspended
metals should be explored and evaluated by Tampa Electric Company
and the metal content of the slag pond discharge should be monitored.
For these reasons, as well as the fact that Tampa Electric Company
could lose its ability to operate this electrical power facility
without a variance, Tampa Electric Company should be granted a
variance from the rules relating to arsenic, chromium, iror: and
selenium.
4-85
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Tampa Electric Company has withdrawn its requests
for variances from the rules relating to minimum criteria,
general prohibition and lead.
RECOMMENDATION
Based upon the findings of fact and conclusions
of law recited herein, it is RECOMMENDED that Tampa Electric
Company be granted a two-year variance from the surface water
quality standards contained in Rules 17-3.061 (2) (a) (arsenic),
17-3.061(2)(d) (chromium), 17-3.121(9) (cadmium), 17-3.121(11)
(copper), 17-3.121(16) (iron), 17-3.121(18) (mercury), 17-3.121(19)
(nickel) and 17-3.121(26) (selenium), Florida Administrative Code,
for discharges from the slag pond for existing Big Bend Station
Units 1, 2 and 3. The granting of this variance should be con-
ditioned upon Tampa Electric Company's agreement to monitor the
metal content of the slag pond discharge during the duration of
the variance, evaluate alternative suspended metals removal treat-
ment systems, and submit a report to the Department of Environmental
Regulation describing the treatment systems evaluated and the costs
and feasibility of those systems within eighteen (18) months of
the effective date of the variance.
Respectfully submitted and entered
August, 1981, in Tallahassee, Florida.
Hearing Officer
Division of Administrative Hearings
The Oakland Building
2009 Ap&lachee Parkway
Tallahassee, Florida 32301
(904) 488-9675
Copies furnished:
See attached page
Filed with the Clerk of the Division
of Administrative Hearings this
day of August, 1981.
4-86
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Copies furnished:
Lawrence N. Curtin, Esquire
Holland and Knight
Post Office Drawer BW
Lakeland, Florida 33802
Louis F. Hubener, Esquire
Assistant General Counsel
Department of Environmental
Regulation
Twin Towers Office Building
2600 Blair Stofie Road
Tallahassee, Florida 32301
Hamilton S. Oven, Jr.
Administrator, Power Plant Siting
Department of Environmental
Regulation
Twin Towers Office Building
2600 Blair stone Road
Tallahassee, Florida 32301
Honorable Victoria Tschinkel
Secretary, Department Of
Environmental Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
4-87
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I
I
1
!
f
/
S Ar V i fj
4
ran-
tf>»cat* tic
O
Source: TECO (1979).
Figure 2-4. Plot plan, Big Band Station.
m
-------
Hillsborough Environmental
Chairperson <
Sally Thompson
Vice-Chairperson»
Dorothea Cole
Secretary:
Joe Murdoch
Treasurer:
Hallie Call?
Coalition
Tampa - Hillsborough County
P.O. Box 2800, Tampa, Florida 33601
ACTIVE
ENVIRONMENTAL
ORGANIZATIONS:
Audubon Society
Save Our Bay
Citizens Aganist
River Pollution
(CARP)
Environmental Con-
federation of
South West Fla.
(ECOSWF)
Gulf Coast Lung
Association
Sierra Club
League of Women Voters
of Hillsborough County
September 1, 1981
Dario J. Dal Santo
EIS Project Officer
U.S. EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
EE:
Comments on the Draft EIS
Tampa Electric Company
Big Bend Unit 4
Dear Mr. Dal Santo:
On behalf of the Hillsborough Environmental Coalition,
which is comprised of concerned individuals and organiza-
tions in the Tampa Bay area — such as Audubon Society,
Sierra Club, Save Our Bay, Citizens Against River Pollu-
tion, Gulf Coast Lung Association, and various other
civic associations, I would like to go on record expressing
our concern with CONSERVATION measures and alternatives
that have not been addressed adequately in this DEIS.
Attached also are written comments by the Hillsborough
Environmental Coalition's Air Quality Chair, Mike Kenney,
and Water Quality Chair, Rich Paul.
It is the Coalition's hope that alternatives to power
plants will be seriously considered in the future. Do we
really need more power plants? Perhaps ifc will be con-
cluded that additional power plaints are not the answer,
especially when we live in a county that has the dubious
honor of having the worst air quality in the State of
Florida. Because of our concern for the quality of life
in Hillsborough County, which is a microcosm of all of the
environmental problems and concerns in the State (such as
growth, land use, air quality, water quality, energy, solid
waste, etc.), we must seriously pursue the avenues of con-
servation and other alternatives. With a year-round tem-
porate climate, Hillsborough County could be a showplace
of the Nation.
We consider it unfortunate that EPA did not see fit to
1 strongly pursue conservation as an appropriate management
" alternative for Big Bend Unit 4. We hope in the future
that conservation and other alternatives to power plants
4-89
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Dario J. Dal Santo -2- September 1, 1981
will b« strongly pursued.
Thank you for the opportunity to comment.
Sincerely,
IS**-
HILLSBOROpGH ENVIRONMENTAL COALITION
Sally Thon^son, Chairperson
Attachemnts: as noted
4-90
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STATEMENT ON AIR QUALITY ASPECTS OF EPA DRAFT ENVIRONMENTAL IMPACT STATEMENT,
Big Bend unit 4, Mike Kenney, Air Quality Chair, Hillsborough Environmental
Coalition
Hillsborough Environmental Coalition is concerned about potential air quality
impact of the proposed project because the Big Bend site is within close
proximity to the nonattainment areas for Ambient Air Quality Standards (AAQS),
a portion of Hillsborough County designated as nonattainment for suspended
particulate matter and a portion of Pinellas County that is nonattainment for
sulfur dioxide.
A review of the DEIS for Big Bend Unit 4 indicates to us the need for clari-
fication on the following points with regard to air quality.
° The modeling for S02 shows that the resultant estimated
3-hour concentration will be 84* of the AAQS.
° The modeling also shows that the impact on the Pinellas
County S02 nonattainment area will be 80% of the allowed HEC-2
applicable emission offset for this facility.
° Those computer modeling estimates are based on the
assumptions that coal with a sulfur content of 3 to 6
pounds per million BTU's will always be available.
The Coalition is concerned that these S0o projects are very close to the AAQS
and they are formulated on a weak and unrealistic assumption; that is, low
sulfur coal will always be available. We feel that TECO must employ some
S02 control technology to insure that the air quality is kept within prescribed
health protection limits.
With regard to particulate matter, the total emission inventory for the new
unit and associated facilities seems excessive. The combined calculated par-
ticulate matter emission volumes are as follows in terms of tons per years:
° coal handling facilities
uncontrolled 900
controlled 120
° boiler 568
TOTAL 1,588
The value 1,588 tons of particulate matter released annually is not compatible
with Hillsborough County's goal of cleaning up the nonattainment area that
lies within a few miles of the site. HEC-3
The modeling for particulate matter as shown in Table 3-12 indicates that the
Big Bend-Units 1-4, with all interacting sources,will reach within 85% of
exceeding the 24-hour standard.
Modeling for particulate matter of the entire facility must be redone showing
the combined affect of the boiler, coal handling facilities and fugitive
dust generated by moving vehicles.
4-91
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STATEMENT ON WATER QUALITY ASPECTS OF. EPA DRAFT ENVIRONMENTAL IMPACT STATEMENT,
Big Bend Unit 4, Rich Paul, Water Quality Chair, Hillsborough Environmental
Coalition
"Acid rain" is emerging as a problem of magnitude in North America. Several area
newspapers have discussed the problem in Florida.(Enclosed in an article from
the St. Petersburg Times, July 26, 1981.) The phenomenon is barely mentioned
HEC-4 in the DEIS. Though coal washing and an SO2 scrubber will be used to control
SO_ emissions#the Big Bend plant will remain the largest SO2 producer in the
County. In a statement of Environmental Impact, we expect a fuller recognition
of the problem by both TECO and the EPA.
The DEIS fails entirely to consider the effect of thermal effluents on the
seagrass/algal communities in the "embayment" area, immediately south of the
power plant location. In this area, the community is already degraded due
co thermal effects (Mangrove Systems, Inc., 1977; 1978 a,b; 1979). Further
damage should be expected, but is not mentioned. In view of the documented 80%
loss of seagrass meadows in Hillsborough County (Lewis and Phillips, 1981), any
further loss or damage should not be permitted.
In addition, thermal discharges have been shown to adversely affect mangroves
HEC-5 311(1 associated fauna (Kolehmainen and Morgan 1972, Kolehmainen 1973, Canoy
1974). No mention is made of possible stress to embayment mangroves.
It is our understanding that as part of the permitting process for the previous
units at Big Bend, an agreement was reached that if the present sheet pile
wall was determined to be too short to prevent thermal effluent from entering
the embayment and damaging biological communities there, it would be modified
or extended. In view of the additional effect likely with the addition of
Unit 4, we would appreciate clarification of the point.
We believe that the problem of thermal loading in the embayment requires further
study. If it is shown to be a problem, modifications to the discharge canal
and/or sheet pile wall should be required.
It is our 'understanding that ash and scrubber sludge storage areas present
potential long-term toxicity problems from heavy metals contamination. TECO
HEC-6 should give assurances of their commitment to maintain these sites in a manner
safe environmentally and for public health, long after the expected life of the
plant.
HEC-7 Finally, we urge that fine-mesh screening should be employed for Units 1 and 2
as. mitigation for some of the unavoidable environmental effects of Unit 4.
Literature Cited
Canoy, M. 1974, Diversity and Stability in a Puerto Rican Rhizophora mangle L.
Forest- Pages 344-356 in Walsh et al (eds.). Proceedings of the international
symposium on biliogy and management of mangroves. 2 vols. IFAS. University
of Florida, Gainesville, Florida, U.S.A.
Kolehmainen, S., Margan, T. 1972, Mangrove Root Communities in a Thermally-
altered Bay in Puerto Rico. Presented at 34th Ann. Meet. Am. Soc. Limnol.
Oceanog., Tallahassee, Fla.
4-92
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-2-
Kolehmainen, S. 1973. Ecology of Sessile and free living organisms on mangrove
roots in Jobos Bay. Rep. Puerto Rico Nuclear Center, Mayaguez, P.R.
Lewis, R.R., and Phillips, R.C. 1981. Seagrass mapping project, Hillsborough
County, Florida. Report to the Tampa Port Authority. 15pp. and maps.
Mangrove Systems, Inc., 1977. Assessment of natural revegetation on disturbed
dredged material islands, breakwaters, and bay bottoms in the vicinity of the
Big Bend Station. Report No. 1, submitted to Tampa Electric Company.
Mangrove Systems, Inc., 1978a. Assessment of natural revegetation on disturbed
dredged material islands, breakwaters, and bay bottoms in the vicinity of the
Big Bend Station. Report No. 2, submitted to Tampa Electric Company.
Mangrove Systems, Inc., 1978b. Assessment of natural revegetation on distarbed
dredged material islands, breakwators, and bay bottoms in the vicinity of the
Big Bend Station. Report No. 3, submitted to Tampa Electric Company.
Mangrove Systems, Inc. 1979. Assessment of natural revegetation on disturbed
dredged material islands, breakwaters, and bay bottoms in the vicinity of the
Big Bend Station. Final Report, submitted to Tampa Electric Company.
4-93
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¦c*
I
v£>
¦P-
P
lorida's rain is almost as
acidic as it3 orange juice
for our lawns and our reservoirs, water and allowed the ground
Rain cleanses the atmosphere of above them to collapse, sinkholes
But it's lethal, not soil swept up by the wind, salt formed. The chemical erosion that
healthful. tossed up from the coastal sea creates caverns and sinkholes has
We don't think much about spray, or gases spewed out of been going on for millions of years.
rain, usually, unless there isn't any.
Normally, rain goes about its busi-
ness of filling our reservoirs and
watering our lawns with such
thoroughness that everything
seems, well, right as rain. So it's
volcanoes.
Airborne debris washed from
the sky by the rain forms dilute so-
demonstrating that the acids in
rain play a normal role in nature
But since the Industrial Revolu -
lutions of alkalines or acids. Weak tion, we've been making more and
acids in rain may form under-
ground caverns by dissolving lime-
easy to forget that rain has other stone. When Florida's recent
more demands on the cleansing
power of rain. Automobiles, power
plants, and sulfide ore smelters are
work to do than to provide water drought emptied those caverns of the main sources of the 50-million
- " -.IK*
«.» *¦
§U E-lisalbesli ieeeer seg! tfHsli ffifeeies
Pastes kg fSsfe iswdea
, ...
tR-SBi it HI
train
• ff; H
T™"
/I pi
can t see it, you can't smell it, you
I*.: : ssSR
¦tellis
escape its lethal presence.
: «•" -¦ -
¦ -I
-------
tons of sulfur oxides and nitrogen
oxides that are emitted in the Unit-
ed States each year. They create a
colossal cleaning job for rain.
We lend a hand in this clean-up
effort only when we're forced to.
Twenty years ago, we of the in-
dustrialized world were strangling
on our own filth, coughing up in
our phlegm what had only just
been coughed up from our smoke-
stacks. We didn't like it, so we is-
sued regulations that say we can't
dirty the air so much that it leaves
people gagging.
Although air pollution is still
with us, we are not allowing it to
reach toxic levels in urban areas.
We are still polluting the air at a
prodigious rate, but we are spread-
ing the pollution over a larger area.
And now the rain has played u
cruel joke on us by turning our
local air pollution problems into a
water pollution problem of global
proportions.
More than 2-million tons of
sulfur oxides and nitrogen oxides
are emitted annually in Florida,
and the total is growing. After
several days in the atmosphere,
these pollutants may turn into su-
lfuric acid and nitric acid. How
thut happens is not exactly un-
derstood. But 9ince the acid9 have
become a part of our rainfall, the
rain in Florida has become more
than 10 times as acidic as it was 25
years ago.
Put enough of that kind of wa-
ter in your fish tank and your aqua-
tic pets will be found floating belly-
up. In the Adirondack Mountains
of New York, where the rain is
more acidic than it is in Florida.
170 lakes are lifeless. Besides steri-
lizing lakes, acid rain can blemish a
tomato, ruin a car finish, or eat
away a marble 9tatue.
But like orange juice that drib-
bles down your chin, acid rain is
washed away by your next bath.
Acid rain is no threat to human
health.
Fish don't like it much, but fish
don't write air pollution regu-
lations. Still, folks in New York did
get a bit testy when they found
some of the finest mountain lakes
in the world devoid of life. New
York Gov. Hugh Carey has prac-
tically threatened to call out the
state militia to halt midwestern
pollutants at the state line, But
there's not much New Yorkers can
do about the Ohio power plants
that create the mess, and it could
take the affected lakes hundreds of
years to recover.
No one knew acid rain was fall-
ing in Florida until 1977, although
it may have begun falling on North
Florida almost a decade ago. No
one knows how acidic normal rain
should be, although it's believed
that before the Industrial Revolu-
tion rain rarely was acidic at all.
Florida's summer rainfall averages
12 times the acidity of what scien-
tists consider to be the most acidic
normal rain. At times, an
individual Florida rainfall may be
80 times as acidic as normal rain.
Almost all of the acid in
Florida's rain is sulfuric acid or ni-
tric acid. Nitric acid falls uniformly
across the state year-round and it
has multiplied 4.5 times in the past
25 years. Sulfuric acid falls mostly
in North and Central Florida and
mostly in the summer. It has multi-
plied 1.6 times in the past 25 years.
At least twice as much sulfuric acid
falls on Florida as does nitric acid,
so sulfuric acid is considered the
primary cause of the state's acid
rain.
Acid rain is like a noise that
goes "bump!" in the night. You
can't quite tell where it's coming
from. You don't know if you've
ever heard it before, because
you've never listened for it. Just
when you've decided there's noth-
ing there at all — bump — there it
goes again.
Only a few scattered measure-
ments of atmospheric chemistry
were made in the early part of this
century. In the 1950s, a systematic
measuring network was estab-
lished in Europe, and in 1959, a
Norwegian fisheries inspector
named Dannevig suggested a con-
nection between acid rain and the
declining fish populations in Nor-
wegian and Swedish lakes and
rivers. In 1968, Swedish scientist
Svante Oden concluded acid rain
was a widespread problem
throughout Europe.
Until 1972, it was not believed
that acid rain was widespread in
the United States. Then Cene Li-
kens and F. H. Borman of Cornell
University reported their belief
that acid rain was falling across the
northeastern United States. Since
then, acid rain has been discovered
across the eastern United States
and in the far West. Patrick L.
Brezonik and his co-workers at the
University of Florida in Gainesville
discovered in 1977 that acid rain
falls across most of Florida.
Rainfall was almost never meas-
ured for acidity in the United
States until the 1960s, and not very
consistently even then. But scien-
tists can approximate the acidity of
rain if its chemical composition is
known. Using such approxima-
tions, Likens and others have con-
cluded that acid rain was falling
over much of the Northest by 1955
and that it has spread since — like
ink from an overturned bottle — to
the south and west.
4-95
-------
In 1977, Brezonik and his co-
workers were the first to systemati-
cally measure the acidity of rainfall
throughout Florida They found
acid rain falling throughout the
state, with the most acidic rain fall-
ing in the north and in the interior.
The half of the state that lies north
of the southern boundary of Hills-
borough County is the worst hit.
But how long has acid rain been
falling in Florida? Without his-
torical data, it would have been dif-
ficult to prove anything unusual
was going on.
Fortunately, two chemical ana-
lyses of Florida's rain were made in
the 1950s, one by the Air Force
Cambridge Research Laboratory
and the other by the U.S. Depart-
ment of Agriculture. Neither study
measured acidity, but inferences
based on the chemical ions meas-
ured by those studies indicate that
Florida's rainfall was not acidic in
the 1950s. One thing the two
studies clearly show is that nitric
oxides and sulfur oxides — the
stuff acid rain is made from —
have increased substantially in
Florida's rain during the past 25
years.
So we in Florida have heard the
noise, decided that we've never
heard it before, and gotten a vague
idea of where it's coming from —
sulfur oxides and nitric oxides. But
so what? Why not drink a warm
glass of milk and go back to sleep?
We might do just that were it not
for the reports of our neighbors —
in New York, Canada, and Scan-
dinavia — about the disastrous
consequences of their not getting
out of bed to take a look around.
Elsewhere, acid rain has caused
fishkills when spring thaws melt
acidic snow and flood lakes and
streams with strong doses of acidi-
ty. Acid rain usually is a less dra-
matic poison, causing gradual re-
productive failures rather than
sudden death. Sometimes acid rain
leaches toxic metals from the sur-
rounding soil and sends in these
poisons to do its dirty work.
Regardless of the method, the even-
tual result is a lake devoid of fish,
mollusks, frogs and aquatic insect*.
Acid rain is an invisible poison; it
leaves no trail of slimy oil or turbid
foam. The lakes are left crystal
clear, sparkling blue and biological-
ly dead.
Lakes are the first places to
suffer from acid rain, but they are
not the only environmental targets.
On land, acid rain can leach valua-
ble nutrients from the soil. It
attacks plants by poisoning the soil
and by damaging the foliage. On
farms, it can blemish tomatoes and
healthy and to be renroducing. But in
measuring nine largeinouth bass from
two acidic lakes, Schulce found they
weighed much less for their size than
largemouth bass from other Florida
lakes.
It's unclear whether the hass are
skinny because of acid rain. Their size
might be because of the added stress
of increased acidity. Or it might he be-
cause acidic lakes have less for the
bass to eat. Schulce found that acidic
lakes have fewer of the floating micro-
scopic plants and animals that are the
basic food for other lake-dwellers.
Those skinny largemouth bass
may be the first known victims of
Florida's acid rain, although Brezonik
calls the data "very inconclusive."
But the good news is that Schulce's
study found that the plants and an-
imals of the Trail Ridge lakes seem
more resistant to acidity than those in
lakes studied by other researchers in
the northern United States and Eu-
rope. That may be because many
lakes and rivers in the Southeast are
somewhat acidic naturally.
The acidity of lake water may not
prove to be the most damaging aspect
of Florida's acid rain, however. Re-
seachers suspect acid rain is leaching
toxic aluminum from the surrounding
soil into the Trail Ridge lakes. The
acidic lakes studied by Brezonik and
his co-workers have "significantly
higher" concentrations of aluminum
than do non-acidic lakes. In sufficient
concentrations, aluminum can
damage the gills of fish and kill them.
Although acid rain has the ca-
pacity to inflict ssvere environmental
damage, researchers say no crisis is
imminent. But no one knows what
might happen in the future as acid
rain accumulates in the environment
and as the rain becomes more and
more acidic. So Brezonik and other re-
searchers have begun another series
of experiments at one of the Trail
Ridge lakes. Three small sections of
McCloud Lake have been isolated so
researchers can test the effects of in-
creased and decreased acidity on the
lake's plants and animals. Nearby,
other researchers are sprinkling soil
plots with simulated acid rain to test
its effects on soil chemistry, micro-
organisms, and plants,
i Environmental policy makers
need to know how much acid rain the
fragile Trail Ridge lakes can handle,
because eliminating acid rain is out of
the question. Instead,officials need to
know how close we can come to the
precipice of environmental disaster
without falling over. For at least the
next 20 or 30 years, doing anything to
curb acid rain is going to be expen-
! sive. The kicker is that it's going to be
! expensive for you.
Florida's acid rain is caused prima-
rily by its own power plants, so any
efforts to comhut acid rain are going
to show up on your electric bills. The
state's electric utility executives are
so concerned about the problem that
they have approved a one-year,
$485,000 study that will measure acid
rain at 14 sites around the state. Staff
members of the Florida Electric
Power Coordinating Croup.- which
represents 17 of the state's electric
utilities, want to make this project the
first part of a three-year, $2.6-million
study.
Even to the state's electric utility
executives, $2.6-million is not spare
change They're considering spending
so much money to keep track of acid
rain because they know the finger of
blame is beginning to turn toward
15 H08IDIAN Jul, 36 mi
V f Hf-it—
HOT SPOTS: Above: The nation's acid
ram areas. Below: Acidity at the
juncture of the Olcefenokee Swamp
and the Suwannee River is fine; in the
Trail Ridge area and in Highlands
County, it's not.
Okefenokee _ -
Swamp .* _ —-s. -_
dwR %
b- » Trail r
— ) \
; J | Highlands \'
County \ r
•t
them. Few of Florida's pollutants
come from the Midwest because our
tropical air masses push most of these
northern pollutants away. Florida
geu a smidgen from other Gulf Coast
states, but most of Florida's acid rain
seems to be homegrown.
The catch is that what we reap
isn't what we've sown.
Two-thirds of Florida's acid rain is
caused by sulfuric acid. Power plants
do not emit a drop of sulfuric acid,
but they do spit out more than one
million tons of sulfur oxides each
year. For reasons no one entirely un-
derstands, once in the atmosphere sul-
phur oxides sometimes change into
sulfates, which later may become
sulfuric acid.
Each smokestack scatters the
seeds of acid rain, but not all the seeds
germinate. There is as yet no wa\^to
trace the sulfur oxides from a particu-
lar smokestack across hundreds of
miles and through various chemical
changes until it becomes acid rain.
That would require sophisticated
computer models that explain what
happens to sulfur oxides in Florida's
atmosphere. For all we know, the pol-
lutants from a particular smokestack
may drift off to sea or fall to Earth be-
fore they can turn into acid rain.
Eventually, we will learn precisely
who is responsible for our harvest of
acid rain, perhaps as a result of the
utility group's study. That will not
make solving the problem easier, how-
ever. Air pollution regulations might
be compared in complexity to the
federal income tax laws. Even within
the same industry, the applicable
regulations differ according to the
age, location and fuel of an individual
plant. Sometimes the pollution con-
trol equipment required for a new
power plant isn't decided upon until
after the riant is built and its smoke-
stack gases are measured
If enough sulfur oxide is measured
around a power plant, new ur other-
4-96
-------
wise, me regulators >.uw -». •
tion. High concentrations of sulfur
oxides are a threat to human health.
But the sulfates formed from sulfur
oxides are not really regulated, be-
cause they pose no known health
threat. Controlling sulfates as well as
sulfur oxides would attack the prob-
lem head-on, but that would require
regulations based on more than just
human health concerns.
The great irony is that one of the
ways we combat air pollution causes
acid rain. An inexpensive way to di-
lute the concentrations of sulfur
oxides near power plants is to build
tall smokestacks which send the pollu-
tants high into the atmosphere where
they are blown away. Unfortunately,
after several days of drifting in the
upper atmosphere sulfur oxides are
likely to turn into acid rain. In
attempting a quick fix to local air pol-
lution problems we have created a
new problem for other communities
many miles downwind.
Current federal air pollution regu-
lations cannot cope with acid rain be-
cause it was practically unheard of
when Congress passed the Clean Air
Act in 1970. The act is up for renewal
this year, and many industry groups
are lobbying to relax emission stand-
ards they say are too costly or unnec-
essary. Keeping these forces from gut-
ting the act will be difficult in light of
the new anti-regulatory mood in
Washington, so expanding the act to
cover acid rain seems doubtful.
Yet environmentalists say their
goal is to revise the act so it can be
u>ed to combat acid rain. The League
of Women Voters, the American Lung
Association, the Sierra Club, the Envi-
ronmental Defense Fund, the Friends
of the Earth, and the Natural Re-
sources Defense Council say their
goal is to revise the Clean Air Act so
that preventing jcid ruin is giien
equal touting to protecting hum,in
health That might me:in banning tall
HOT SPOTS: Above: The nation's ocid
roin areas. Below: Acidity at the
uncture of the Okeienokee Swomp
md the Suwannee River is (me,- in ihe
Trail Ridge area and in Highlands
County, it's not.
smokestacks as a pollution control
measure and controlling the emission
of sulfates as well as sulfur oxides.
Whatever the outcome of this na-
tional debate, Florida's acid rain
probably will get worse. More and
more sulfur oxides will be dumped
into Florida's sky during the next 20
to 30 years. One reason is that more
power plants will be built, many of
them in the interior of the state where
their emissions are less likely to drift
out to sea. Another reason is that
Florida will be producing more of its
electricity from coal — a notoriously
dirty fuel.
New power plants must meet fair-
ly strict emission standards, so as our
present power plants are replaced,
emissions should slack off. But many
plants will be in use for another 30
years. As many as 4'2 oil-fired plants
could be converted to use coal, and
they might not have to meet the strict
standards that new plants do. Impos-
ing stricter standards on such con-
verted plants would raise the cost of
conversions substantially, perhaps
eliminating the advantage of convert •
ing from expensive foreign oil to
cheaper domestic coal.
. Utility executives say too little is
known aboutacid rain to justify tight-
ening emission controls. Charlie Hen-
derson, a Florida Power & Light
executive who heads a subcommittee
on acid rain for the Florida Electric
Power Coordinating Group, chal-
lenges the interpretations of some re-
searchers. He points out that the oft-
cited lack of acidity in the lakes and
rainwater of 20 years ago is based on
circumstantial evidence.
"There are a lot of so-called facts
as to whether there is a trend," Hen-
derson says. "We feel there is a lot of
supposition out there."
Henderson and other utility execu-
tives chafe at the idea of putting flue-
gas desulfurization scrubbers, an
effective but expensive emission con-
trol, on coal-fired plants. "You could
put scrubbers on and have no de-
crease in acid rain," Henderson says.
"That would be a very expensive les-
son."
An equally expensive lesson, how-
ever, might be to ignore the problem
until a crisis develops. One economist
told a Senate hearing last year that
acid rain causes between $500-million
and $50-billion in environmental
damage to the United States annual-
ly. There is no estimate on what it
might cost Florida.
Those nine skinny largemouth
bass yanked from two North Florida
lakes last year may not mean much to
you now, but if their kith and kin
should eventually die, you may have
to put your money where their gills
are. (!'
Elizabeth Connor and Wolt Woolon are
free-lance wriTeri Jiving in Gainesville
4-97
IVff' i i
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
ER 81/1412
SEP 3 1981
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
We have reviewed the Draft Environmental Statement for Issuance
of NPDES Permit for Big Bend, Unit 4, Tampa Electric Company,
Hillsborough County, Florida and have the following comments.
Our Bureau of Mines Mineral Industry Location System (MILS) data
indicate that phosphate, limestone, and peat deposits are actively
mined in the region. However, the draft does not address mineral
resources or mineral production. The final report should acknowledl «>
LJUI-1 existence of mines and potential mineral resources within the
project area and should define any adverse Impacts that the propose^
action may have on mineral production. If no mineral resources wil.^
be affected, a statement to that effect should be incorporated in
the report.
Page A-ll, paragraph M. Although we note that our recommendations
for preventing adverse impacts to the West Indian Manatee are dis-
cussed in the draft NPDES permit, we are concerned with the wording
of this paragraph. As written, it states that the permittee shall
coordinate and work with the Department's Fish and Wildlife Service
(FWS) to mitigate potential impacts "should significant impacts
occur to the manatee." Our FWS recommendations were intended as
DOI-2 a preventative measure to avoid impacts, not as a cure to be imple-
mented after significant impacts had occurred. Ninety dead aanate^a
have been reported and discovered in the southeast from January 1,
1981 to July 31, 1981. Eighteen of these deaths have been positiv^^y
linked to collisions with boats or barges. Boat traffic has
undoubtedly contributed to more deaths for which the cause of
mortality cannot be absolutely determined. Considering the critic^j
nature of this problem, we believe it is inappropriate to delay
Implementation of our recommendations until after the impacts have
occurred.
4-98
-------
Mr. John E. Hagan, III
2
We therefore urge that paragraph M be written to require the
closure of the boat ramp from November 15 to March 30. If this
is not accomplished, we will reinitiate formal consultation
pursuant to Section 7. The prevention of injuries and deaths
of manatees is very important. We believe that the applicant
would be able to relocate this boat ramp to an area that is not
utilized by this species.
Sincerely,
%ruce Blanchard, Director
Environmental Project Review
4-99
-------
A-95 #201-81; TECO Big Bend Unit 4 Draft Environmental Impact Statement,
Hillsborough County
CtEMMGHOUSE REVKUE
The Environmental Protection Agency has requested review and comment on a draft Environ-
mental Impact Statement regarding issuance of a New Source National Pollutant Discharge
Elimination System Permit for Tampa Electric Company's proposed 417 megawatt capacity
coal-fired steam electric generating plant at the existing Big Bend Complex in Hills-
borough County.
K
O
(M
I
cc
o
CO
I
cc
o
Local Comments Requested From;
Hillsborough County City-County Planning Commission: See attached letter dated July
23, 1981.
City of Tampa Planning Department: See attached letter dated July 21, 1981.
Council Comments and Recommendations
This project has been reviewed for consistency with the Council's Areawide Water Quality
Management Program and the Council's adopted growth policy, the Future of the Region.
The proposal has been found to be consistent with Council policy to ensure that public
and semi-public facilities are planned as an integral part of community development
and redevelopment in areas suitable with respect to the protection of the environment
and energy efficiency.
The purpose of this EIS is to identify the environmental problems caused by the location,
capacity, fuel and by-products of this electrical generating facility. It is evident
that while the plant will have an impact on the environment of the Tampa Bay Region,
all necessary steps have been taken to minimize this impact. Stack scrubbers will be
employed to remove fly ash and sulfur dioxide from emissions, a fine-mesh screen will
be used to prevent intrainment of marine organisms within the cooling water intake
canal, an earthen-diked disposal cell will be constructed for the on-site disposal of
gypsum and fly ash.
I
The socioeconomic benefits to be derived from this project will be the provision of
sufficient back-up generating capacity so that TECO and the customers within its
service area can benefit from availability of sufficient electrical power during peak
load times. This in turn will eliminate the necessity of TECO purchasing power from
other electrical utilities in and out of the state.
This project is regionally significant and no regional concerns have been identified
during the review which would preclude its approval. It is therefore recommended
that this proposal be approved for funding. Further, it is recommended that any
comments addressing local concerns be considered prior to approval.
1 Committee adopted September 4, 1981.
Commissioner Jan Piatt, Chairman
Clearinghouse Review Committee
4-100
-over-
tampQ boy regional planning council
9455 Koyer Bouieva'c! St Petersburg, FL 33702 (813) 577 5151 Tampa ?'M 93'
-------
»r
county coufrrxxac
p.o. box 1110 e.;
TAMMk. R.3M01 ~
HILLSBOROUGH COUNTY CIYY.COUNTY PLANNING COMMISSION
JOE CHILLURA, JR. RONALON. SHOW
CHAIRMAN BMCUmt ML I UP
ROBERT EDWARDS
VICE CHAlWMAN
DR GORDON BRUNHILD
MEM6EP *T LARGE
HENRY c. BROWN
DP ROBERT CATLIN
MANUEL FERNANDEZ
WARREN JOHNSON
BARBARA MYRES
FITZ RAWLS. JR.
WILBERT WILLIAMS July 23, 1931
MEMO TO: Mike McKinley, T3RPC
FROM: Hars Zarbock, Community Planner.
SUBJECT: A-95 No. 201-81 TECO Big Bend Unit 4, DEIS
The referenced expansion of the existing power station is in
conformance with the Horizon 2000 Plan.
Although the fourth unit will increase the station's environmental
impact through air pollution, thermal effects and entrapment and CR-4
entrainment of marine organisms the recent 316 Demonstration has
indicated that Best Available Technology will be used to minimize
these impacts. TECO should be encouraged to continue their bio-
logical monitoring program.
MM/1 c
cc: Christie Supp, ODC
4-101
A CITY-COUNTY AGENCY SEPVING THE CITIES OF TAMP*. PLANT CITY, TEMPLE TEWMC£ AMD TW6 COUNTY OF HWXSBOPOUOH
AN AFFIRMATIVE action — EQUAL OPPORTUNITY EMPLOYE*
-------
July 21, 1981
Mr. Michael R. McKinley, Chief
Governmental Services Division
Tampa Bay Regional Planning Council
9455 Koger Boulevard
St. Petersburg, FL 33702
Dear Mr. McKinley:
Re: TBRPC A-95 Clearinghouse Review No. 201-81; TECO Big Bend Unit 4
Draft Environmental Impact Statement, Hillsborough County
This project Is compatible with all existing plans.
-5
Thank you for the opportunity of reviewing this project.
yuan. T. Smi th
Director of Project Planning
and Grants Administration
/mlw
4-102
City Hall Plaza SE • Tampa. Florida 33602 • «> a/*"*-"
-------
SIERRA CLUB
FLORIDA CHAPTER-
1601 NW 35 Way
Gainesville, FL 32605
Sept. 14, 1981
Mr. Dario D51 Santo
EIS Branch
U.S. Environmental Protection Agency
3^5 Courtland St. NE
Atlanta, GA 3°365
Dear Mr. Dal Santo:
The Power Plant Siting Committee of the Florida Chapter
Sierra Club has made numerous comments to EPA regarding the
EIS for the TECO Big Bend 4 power plant. Since some of these
comments have been sent to EPA well in advance of the issuance
of the Draft EIS and the subsequent public hearing, I would
like to make sure that all of these comments are included and
addressed in the Final EIS. Copies of our previous comments,
all of which have been sent to EPA in the past, are enclosed
for the formal record.
1. January 20, 1981—comments on 316 hydrology and biology SC-1
2. February 14, 1981—comments on 316 hydrodynamic modeling SC-2
3. March 28, 1981—comments on replies to questions from SC-3
TECO
4. July 23» 1981—letter to FDER stating we are not con- SC-4
vinced of negligible environmental impact from the
once-through coaling (copy not sent to EPA).
December 131 1980—comments to FPSC where we stated SC-5
"Neither the TECO Site Certification Application nor
the PSC preliminary report of October 15 thoroughly
identify or evaluate the conservation measures reason-
ably available to TECO."
6. February 1, 1981—letter to EPA outlining our concerns SC-6
with the Draft EIS structure which would not adequately
address alternatives.
7. August 19> 1981—Sierra Club statement (with Attachjfteftt< SC-7
I) which expressed concerns with the environmental ' .
-------
impacts of the TECO Big Bend k plant and which showed
an alternative that was less environmentally damaging.
Before concluding, let me reiterate the position of the
Florida Chapter Sierra Club on the EIS for the TECO Big Bend 4
plant:
Under NEPA, EPA has a legal responsibility to identify and
study all viable alternatives. This has not been done, and
the Sierra Club formally requests that EPA adhere to the require
ments of the law in formulating the Final EIS for the TECO Big
Bend k plant.
Thank you for your consideration.
Yoi ' "
Barney L. Cllpehart f
Chairman, Power Plant Siting
Committee
4-104
-------
SIERRA CLUB
FLORIDA CHAPTER
1601 NW 35 Way
Gainesville, FL 32605
January 20, 1981
Mr. H.S. Oven, Jr.,
Power Plant Siting"Administrator
Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 3230^
Dear Mr. 0ven»
Our consultant, Mr. D.S. Graham, has completed his
review of the documents submitted by TECO for the 316
Demonstration Study. A copy of his comments on SS 4-8
is enclosed.
On November 10, 1980, I sent you a handwritten copy of
Mr. Graham's earlier comments. ( A typed copy will be
forwarded shortly.) Have you had an opportunity to review
these comments yet?'
Yours truly,
Power Plant Siting Committee
Chairman
cc: EPA (with enclosures)
TECO (with enclosures)
Tampa Bay Sierra Club Group (with Enclosures)
4-105
-------
COMMENTS ON THE BIOLOGICAL SECTIONS OF THE
TECO CERTIFICATION APPLICATION
-Sierra Club-
1. General Comments
Comments on the material presented in ff 4-8 of. -the TECO
316 a and h Demonstration for Big Bend station are pre-
sented herein. Previous comments have been submitted re-
garding the hydrodynamic/thermodynamic modeling aspects of
this study. The intent here is to take a more general over-
view than was provided in the previous review.
The Applicant has provided an overwhelming amount of
biological data. A general comment is that the data appears
to be poorly drawn together so as to present clear lucid
conclusions. A preliminary attempt to do so will be made
here. Furthermore, the conclusions are based upon some dubi-
ous assumptions and methods from an analytical point of view
(i.e. the validity of the hydrodynamic and population model-
ing) , and may be invalid to the extent that these supporting
assumptions err.
2. Description of the General Problem
The general problem is poorly outlined in the study and
needs to be clarified in order to assess the analysis, It is
proposed to enlarge an existing plant, therefore
1. some impacts are already occurring
2. these will presumably be increased
4-106
-------
2
3, mitigation measures can be applied to the in-
crement, or to the entire plant,
We support plant-wide mitigation. Since the plant already
exists, some site-specific impact data can be gathered.
The impact zones and types can be dissaggregated as
A. Intake i) entrainment
ii) impingement.
B, Outfall i) discharge canal and near zone
ii) dilution pump and canal
iii) near-plant thermal effect area
iv) far-plant effects (primarily
from entrainment).
The dilution pump studies and other biological data
indicate severe effects and high mortality in the discharge
canal area. This area then is to be "written-off," and the
major effects of the larger plant will be to extend its
relatively small impact area. The far-field area will be
impacted by losses of due to entrainment and im-
pingement. We have noted problems with the DISPER-1 model-
ing of this effect earlier, and this has apparently been de-
emphasized. We do have some reservations about the rather
simple population model used, and this will be discussed
anon.
The area of largest incremental impact is the near-plant
coastal zone. As pointed out in our earlier submission, this
is just the area where the results of the far-^field (CAFE)
and discharge-canal models are least valid—largely by virtue
of inappropriate grid size in the larger model and some rather
4-107
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3
severe and likely inappropriate assumptions in the near-
field. Any conclusions based on either model as they affect
the near-plant zone are not considered reliable by us,
This leads to the conclusions regarding the incremental
temperature analysis. Quite frankly, we doubt that the pat-
terns represented by Figures 6,2-2 and 6,2-3 exist. No
field data to substantiate them are given in spite of the
existence of an operating plant. Further, as noted before,
we doubt that the type of data presented in Table 6.2-2, or
referred to on p, 2 of the thermal effects study, is valid
insofar as a steady-state model was used in an area where
tidal hydrodynamics dominate (at lower values of AT, at
least), Hence, in order not to be overly repetitive, any
conclusions about biological response based on hydrodynamic
modeling in the area just beyond the discharge canal are
viewed very skeptically by us.
The proposed plant will use the same discharge and in-
take system as the present plant. The dilution system appears
to have a very high mortality rate at some times, hence its
effect may not be very beneficial. The net motion in the bay
is not great, hence there is some chance that the water may
cool and recirculate locally. No study of this pattern has
been investigated, by a dye test or other means, (The com-
ments regarding the dispersion coefficient on p, 7.1-5 are es-
pecially confusing when viewed in this context),
Finally, as noted later, the intratidal variations and
short-term thermal variations have been ignored in the
4-108
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4
biological analysis (with perhaps the exception of some very
unusual comments about gradients on p, 7,1-6), and these mav
also need to be addressed.
3. Approach
The Demonstration is reviewed in the context outlined by
EPRI in its report:
Methodology For Assessing Population and Ecosystem
Level Effects Relating to Intake of Cooling Waters,
EPRI-EA-1238, Nov. 1979.
The basic approach, as outlined therein, is
1. Estimate the total annual impingement and en-
trainment mortality for each species.
2. Estimate source waterbody abundances.
3. Develop a relationship between plant mortality
and the population.
4. Evaluate the role of potentially impacted popu-
lations in the biotic community through food"
webs and community analysis.
5. Determine the need for comprehensive analyses.
To the extent possible, the text of the Demonstration itself
will be followed.
Section 4
In section 4 a voluminous amount of data is presented
with a miniscule amount of linkage, summary, or conclusion.
The first thing that needs to be addressed is the valid-
ity of the sampling scheme itself. This has both spatial and
temporal aspects.
Samples were apparently taken at 2 week intervals/ with
day and night samples being taken. This assumes
4-109
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5
1) that variations at a given point in the Euleri-
an frame used over a tidal cycle were small
relative to those over a fortnight,
Explicitly, that ^ ^^
XT ~
and hence that u
.£». ^ u. 2*L
it ^ 3Xc
where * is the quantity being measured at the sampling sta-
tion. We would like to see intratidal data to substantiate
this premise.
2) that diurnal variations in * are large relative
to tidal ones.
Since the diurnal period is 24 hrs.^and the tidal is
about 25/ we do not see how the sampling technique used could
verify this assumption.
Further, we see no data delineating the thermal plume
in the field in both plan and the vertical so that sampling
locations relative to it would be known. As noted, we have
no confidence at all in the near-field model predictions be-
yond the entrance of the discharge canal.
If the F-ratio data in Tables 4.5-7, 10, 11, 12, 13 are
regarded, for instance, it can be seen that trip variance is
often large compared with station variance. Can this trip
variance be further subdivided into intratidal and nontidal
variations? If so, would the intratidal variation increase
the F-level of the station variance?
The following conclusions are drawn from the masses of
analyzed data in 4.
1, On pp, 4.4-4 and 4,4-5 it is noted that
4-110
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6
pollution tolerant oenthic organisms thrive in
the canal discharge areas. For instance, C.
capitata comprised 41% of the samples in tEe
canal, yet 1% away from it.
2. Density values are lower in the canal.
3. Note the scales differ on the figures in Figure
4.4-9, and that the discharge canal area has
lower values.
4. On p. 4.6-2 it is noted that few fish were
caught in the discharge canal area (stations
TB-1, TB-6).
5. Finally, if the F-ratios for some RIS'g are
examined, it is seen that the impact, by sta-
tion, appears to be very stage-dependent. See
2oca on Table 4.5-13 for instance'. This in-
dicates that a rather sophisticated population
model is required.
Given the mass of biological data presented, very little
of a summary nature is provided to tie it together. In par-
ticular the differences between assemblages within and without
the plume are not highlighted. Even more surprisingly, it is
not clear just which stations were inside and outside of the
plume on a given sampling date, or on the average. All that
is clear is that stations which were definitely in the thermal
plume were adversely impacted.
Comments on Section 5
Section 5 is somewhat more cohesive and coherent. We
have no argument with the RIS's chosen. In general, however,
it is not made clear that the species are to be only repre-
sentative. Saying that there is-, no impact "to - oysters since few
are in the area is irrelevant since the oyster is supposed to
represent sessile organisms which definitely would be impacted
because of their lack of mobility.
4-111
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7
The mortality appears to depend not only upon the value
of the temperature, but also upon its rate of change. Note
comments to this effect in paragraph 5, p. 5.2-2, and the
last sentence of p. 5.2-9, among others; as well as in Tables
A.-6. Rapid changes in temperature would be expected to oc-
cur near the edge of the plume as it is tidally advected.
These effects also need to be discussed and evaluated.
A final comment on section 5 is that both shrimp larvae
(p. 5.2-9) and spotted seatrout larvae (p. 5.2-30) are not
entirely passive, and hence some type of multilayer approach
might be needed to describe their dynamics. This is not
warranted for this investigation, however.
Section 6
Comments have already been made in other submissions
about the need for biocide modeling and toxicity assessment,
as distinct from nearshore thermal modeling. Our dubiety
about the data as presented in Tables 6.1-1 to 3 has already
been noted, and the reasons given previously in our review of
Amendment 5. The plots shown as Figures 6.1-5 and 6 need to
be compared to field data to be convincing. Vertical (x-z)
information should be illustrated also. Note that the near-
field model is 2-dimensional (r, z) and steady-state.
The two-dimensionality in plan (r, ^) shown in Figures 6.1-5,
6 is assumed and not proven. We surmise more tidal advection
and dispersion occurs, more tendency to hug the shore, and
more re-entrainment than is indicated,
This may be the appropriate place to discuss the fine-mesh
4-112
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8
screen, intake, and discharge, The PV costs of a screening
system, including retrofit, is given as $18.2M on pr 6.2-7.
It would be absurd from a scientific context to leave the
existing units unscreened if it is determined that screening
is needed for the new one. On p. 7.4-1, the one-sentence
line that
since the station's effect on aquatic populations
is not adverse, the utilization of a fine-screen
mesh is not warranted
is presented. This is a nice try, but we must challenge
this assumption and conclusion. The challenge is based on 2
points
1) As noted in our review of the data of $4, adverse
effects do occur; the question is whether their
degree is significant enough to justify a
$18.2M expenditure. We challenge the Applicant
to demonstrate that no adverse effects occur,
as alleged on p. 7.4=I.
2) The statement is based upon results from the
population modeling, which are inadequate to
support it; and from the hydrodynamic modeling,
which, as described, is incorrect in many re-
gards .
Now, regarding the intake structures as illustrated in the
new specs provided as Figure 6.2-4, the general layout and
approach look good. However, unless the local dispersion
rate were very large (which it isn't) in the vicinity of the
adjacent canal where the screened organisms are to be depos-
ited, it would appear that all passive organisms there would
eventually be re-entrained on the screen, by virture of the
configuration of the intake grain from Fishhook Spoil (Fig.
6.2-3). We accept the screen-trapping and transport system
outlined by TECO as being promising and likely very effective,
4-113
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9
but it also seems obvious that the entrained organisms^be
disposed of well away from the intake channel and in dilute
enough quantities so that predators are not attracted to the
POD. A dye test in the proposed disposal canal would indi-
cate what the re-entrainment rate is.
The current and proposed discharges just do not seem to
be hydraulically optimal. A discharge alternative placed
farther offshore, and preferably in a multiport format,
should be investigated. We surmise the current discharge
system leads to poor mixing rates, a tendency to hug the
shore, and high re-entrainment rates. We would like to see
some field data on the characteristics of the present plume.
The near shore model results (in plan), as presented,
cannot show any change in plume behavior following dredging
work by Corps (Note S. Palmer) . £no variation$
We would also like to see more field data on the ver-
tical behavior of the plume, on a transient basis, to de-
termine the validity of the data presented as Tables 6.2-1-3.
This can then, be compared to transient mortality data, such
as 0.74°C/hr TLm presented for oyster in Table A.6.1, Ap-
pendix 6, to determine the true extent of benthic impact area.
Section 7
A major pivot of the conclusion of no significant bio-
logical impact is the population.modeling. Unfortunately,
the population modeling, as presented in Section 7, appears
to be deficient or simplistic in several regards; including:
1) natural mortality is not differentiated from
conditional plant mortality
4-114
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10
2) density dependence and growth compensation are
ignored
3) the effects of the lost organisms to their
predators are not analysed
4) the mathematical model presented is somewhat
tr.-.vial.
First it is assumed that equilibrium populations exist
both before and after the plant for each species. Are all
RIS's in equilibrium? Is the manatee? Do oysters require
2 breeding adults, being hermaphrodites? The data in ^4
show stage-dependent mortality. These are only grossly ap-
proximate in this model.
No charts or tables telling what E and s values were
used, or whence they came, could be found in the Demonstra-
tion. What are they?
The mathematical formulations to arrive at eqn. 7.1-4
are not that difficult. Regard eqn, 7.1-5
but, from 7.1-3
^ » S, + £ * S, * ^
By definition Na = Se Ne
Hence equation 7-15 is not a development from eqn. 7.1-1/ but
merely a restatement. To solve the problem one needs to know
Ne, F, E, and Sr These are related by equation 7.1-4, in
part, so that either Ne or F can be neglected. At best,
then, this model will predict Na from Ne, or vice versa.
Changes in population structure, or relative species sizes
and diversity, cannot be found. Neither can transient long-
term shifts. EPRI (op. cit,) notes: Thermal power plants
4-115
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11
rormally operate on a near continuous basis, particularly
at multi-unit sites, with an expected life span on the order
of 40 years. The effects of cropping, therefore, will be
experienced by fish and major invertebrate populations on a
continuing basis. When estimated short-term effects are
small, an inference is generally made that the long-term ef-
fects will also be small. This reasoning is sound while the
effects are very small, however, at moderate to high levels
of cropping the annual loss could change overall population
levels or other characteristics of the population. Because
fish and major invertebrate species may have long generation
times, the response of a population to continuous cropping
may not be apparent for years, and many additional years may
pass before the population stabilizes with respect to intake
cropping.
Another assumption is that populations are uniform through-
out the bay, and not local or concentrated near the shore.
Comparisons are made on the basis of proportion of total area,
or proportion of total volume. The validity of such analyses
is not entirely self-evident. Another aspect is the ratio of
intake mortality to internal generation and boundary fluxes.
If no density effects are assumed (and they are not), then the
changes induced by plant mortality cannot be made up by higher
internal source generation. If equilibrium populations of the
same level are to exist, then boundary fluxes must be higher
to compensate. These aspects are not discussed.
Dispersive fluxes are mentioned in paragraph 1 of
p. 7.1-5. It was stated last fall that we do not readily
4-116
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12
comprehend the validity of this argument. We requested an
explanation. In point 6 of his letter of Sept 16, 1980,
Dr. Johnson again reiterated it was so, but no proof was
given. We may just have clouded vision on this argument,
but we would still like a rigorous proof of this argument
(i.e. mathematical). The validity of both the heat effect
and population analyses depends upon it. It is not entirely
self-evident to us that a higher dispersive flux would not
result in greater mass transport rates from the discharge to
the inlet in the absence of significant net advection.
Similarly, the argument regarding areas of reduced con-
centration stated in paragraph 4 ("The base case...") of
page. 7.1-5 is also not self-evident. Figure 7.1-1 is missing
from our Demonstration, so this may be the cause of the prob-
lem. The areas of influence of entrainment, depicted in
Figures 7.1-1 thru 4, certainly do not appear small or in-
significant with respect to the areal extent of Tampa Bay.
We are very confused by the statement near the top of
p. 7.1-6; viz.:
This is not evident in the data presented; kindly illustrate
it more clearly. Further, it usually follows that effects
are proportional to gradients in all environmental engineer-
ing work. Kindly demonstrate rigorously why the impact of *
standpoint, a change in * will result in either time or
The area of influence is affected by the spatial
pattern of concentration with the steeper gradi-
ents having smaller areas of influence.
would
From our
4-117
-------
13
space having an impact. Usually, the greater the change in
*, the greater the impact, i.e.,
d (jc***c.T ) cP £ c/ ) dL
now for changes with respect to space
3X "3X J *
will occur in a timescale proportional for the character-
istic velocity—
5 * . u = ^ **-
3 x A At ^-fc
F»t Afr = c««.w*r r/wfAj a **i
i.e.
-------
14
units per annum.
The cumulative impact, p. 7.1-8, should include evalu-
ation of other losses due to other plants, water pollution,
dredging, etc.
Section 7.2
Comments about our skepticism of this thermal modeling
have already been made. It follows we do not accept conclu-
sions based on them.
In ^7.2.1.1. the comment appears:
While a small portion of the larvae in the
Bay will be killed by entrainment, this loss is
unlikely to adversely affect the Tampa Bay oyster
population.
Such unproven comments are of no value. Prove it! As
noted previously, on p. 7.4-1 it states
the station's effect on aquatic population is
not adverse
yet on p. 7.2-4 it states that 5,275 adult shrimp will be
lost, and 98,000 will be impinged. Similar data are given in
^7.2 for other RIS's. How can these not be adverse?
Arguments about proportional areas are also not convinc-
ing unless it can be shown that distributions are uniform.
If macrophytes are nonuniformly distributed, then is it not
likely that many fish are also?
Note on p. 7.2-7 that
molting larvae are intolerant of sudden
fluctuations of temperature and salinity.
Would this not occur at the edge of the plume? Has this
been factored into the mortality rate?
Note that explicit data for natural vs. plant-induced
4-119
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X3
mortality are not given here.
Section 7.3
Benthic effects depend upon the area the plume touches
the bottom to a large degree. We have stated some reserva-
tions to these predictions in an earlier review. Calibra-
tion with field data for the current plume distribution is
required.
P. 7.3-2, 2nd last paragraph, ("In summary,.."} indi-
cates better mesofield modeling and data are required to
evaluate benthic effects there. This is the area where the
significant impacts will occur.
The linear model presented on p. 7.3-4 is not developed
or justified. Why is a linear model valid? Are the rela-
tionships linear? Why should a "quadratic effect of sedi-
ment grain size" have a linear effect? What meaning do the
numbers in Table 7,3-1 have if the relationships are not
linear? Should environmental impact be based on linear con-
cepts;^natural systems approximately linear?
The conclusions reached in^7.3.3 depend on the near-
field model results, which are uncalculated, and which there-
fore cannot be substantiated or accepted.
Section 7.4 Fine Mesh Screening
Note that
1. It is accepted herein that the screen works.
2. It is stated that the survival is life-stage
dependent, but values are not given,
3. It is stated that the effect on aquatic popu-
lations is not adverse, although data show it
is.
4-120
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16
Hence, the Sierra Club does not concur that utilization
of the fine mesh screening is not warranted, it recommends
1. the screening be utilized
2. the organisms be discharged far from the intake
area
3. the" dilution pump be turned off, or similarly
screened
4. if the dilution pump is turned off, then alter-
native discharge configurations affording bet-
ter mixing be investigated.
The sentence at the bottom of p. 7.4-1 is a sleeper.
The methods and data presented do not justify this conclu-
sion, in our opinion.
Section 8
No comment, would be redundant. The hydrodynamic and
population modeling upon which these conclusions are based,
are of dubious validity. The overall concept is logical,
though.
Recommendations
1. the nearshore model be rechecked, and calibrated and com-
pared with field data
2. a fine-grid far-field model be developed to simulate the
mesofield
3. dye tests be undertaken to determine re-entrainment from
the discharge, and entrainment from the canal where the
screen organisms are to be dumped
4. intratidal samples be taken near the edge of the plume
5. the 3-D extent of the plume be measured in the field over
tidal cycles
6. the fine screen mesh program be continued
7. population modeling be based on density effects, and en-
ergy flux considerations for effects of killed larvae
4-121
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8. separate modeling and toxic analysis of biocides be made.
It is our opinion that the approach is conceptually correct.
The Demonstration, as presented, is still not convincing,
however.
4-122
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If
Comments on Possibly Toxic Wastes in Amendments 3 and 4
1. Surface Discharges
In the response to Question 3 in Amendment 4, it is
noted that blowdown; (and FGD bleed) streams will ultimately
be placed in the discharge channel. This is admittedly a
better disposal mechanism than routing to Jackson Creek.
Further in 5.2.1.1. of Amendment 3 a possible variance op-
tion is requested. In 5.2,1.4. only a qualitative expecta-
tion that blowdown will not have a significant effect is of-
fered.
As noted in previous applications, we have never con-
sidered it wise to underestimate the effects of dissolved
toxics upon aquatic environments. While modeling for ther-
mal discharges has been described, the mixing zone charac-
teristics for the blowdown are poorly covered, as are any
convincing demonstrations that these streams will have no
effect upon the aquatic environment after mixture. Could a
lethal dose toxicity test be performed on RIS's and macro-
phytes found near the plant at ambient temperatures to ensure
there will be no effects?
2. Groundwater Discharges
Most of the groundwater conclusions depend upon assump-
tions about the coal, ash, and FGD content. These cannot be
checked until the system is in operation, Therefore, we
recommend close scrutiny of monitoring wells by the DER af-
ter the system is in operation to ensure these assumptions
prove correct.
4-123
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SIERRA CLUB
FLORIDA CHAPTER-
16')t NW Wn.y
fl 32605
February l4k 1981
Mr. H.S. Oven, Jr.
Power Plant Siting Administrator
Dept.. of Environmental Regulation
260Q Blair Stone Road-
Tallahassee, Fix 3230^
Dear Bucks
On November 10, 1980. we sent some? handwritten comments
to, you front• our consultant Mr. B.TJ. graham on the TECO Big Bend
^ 31.6 Demonstration. These comments have new been typed and
w& have enclosed this copy i'or you. Please add them to our
previous comments. IFianir you-
• < •. s*- I -k . f ¦
'^^^r.-Bacnay I»- Cajj^hart.
¦"^^ Powerk Plarrfcr Siting" Gommitirae
.. r
• ¦*%£'& '••'• *-* ' ¦."' ;-r' * '\fl062»%fc/ '
-------
REVIEW OF AMENDMENT 5 TO TECO
316 DEMONSTRATION REGARDING
HYDRODYNAMIC MODELING
- SIERRA CLUB -
Introduction
Briefly, the Sierra Club submitted a response to the
draft TECO 316 Application in which certain critical comments
were made of techniques used in the hydrodynamic modeling of
Tampa Bay. These were further expounded on at a meeting at
TECO Headquarters, in Tampa, on November, 1979.
Responses to these comments have included letters
from Dr. Johnson of TECO, of August 11th and September 16,
1980, and issuance of a.vu Appendix 5 to the Demonstration.
These materials are teviewed herein. The Sierra
Club appreciates the opportunity to comment on these studies
and hopes its efforts will assist in the regulating and lic-
ensing procedures.
General Comments
Relatively minor changes have been made with respect
to the modeling efforts originally described by TECO. The
near-field model has been changed to more accurately simulate
a high-Richardson-number environment, and this is laudable.
The model used is still steady-state and neglects certain
important dispersive terms.
4-125
-------
Some changes appear to have been made In the far-field
modeling, but the instability problems inherent in the grid
still appear to plague the model. While the method of compu-
tation is unclear, the net advective flux problem appears to
have been corrected. The large eddy viscosity coefficients
required to obtain numerical stability still render some re-
sults dubious, in our opinion.
This review has been made difficult by non-standard
symbols and nomenclature, and unwarranted changes in both
notation and coordinate systems. This will be discussed
anon.
III. Near-Field Modeling
This material refers to Section 4.5.1 of Appendix
5 of the TECO 316 Application.
First, we are pleased that the near-field model was
altered to better simulate appropriate Richardson-dominated
dynamics. Comments will be made, to the extent possible, in
the order of the text.
1. The reference to Lean and Willock (1965), on
p. A»5.1.-l is an obscure publication. We cannot
judge its validity until we are able to locate a
copy.
The slack tide assumption (p. A.5.1.-2) renders
the model steady-state. Tidal conditions are
inherently non-steady; therefore, a lot of inform-
4-126
-------
ation is lost in the averaging. Use of a steady-
state model must be justified on the basis of what
the model is being used for. Presumably, it
should be demonstrated that the intratidal var-
iations in heat at a point in the near-field do
not affect the biota. Since we surmise that
intratidal variations will exceed non-tidal
variations in this region of strong thermal
gradients, the validity of this assumption is
not completely self-evident to us. Finally,
averaging over a tidal cycle (or neglecting it)
will induce rather large "apparent" dispersive
fluxes. As will be shown presently, these are
not in the model.
3. The radial flow assumption implies no flow
separation* This assumption is usually valid
for intakes, but not for discharges.
4. A constant heat loss rate (if conservative)
is reasonable. It is not in equation A.5.1.-4,
however.
5. The use of y as the vertical coordinate (pre-
sumably) in equation A.5.1.-1 is non-standard
to oceanography. Also, note that both math-
ematical symbols and coordinate systems are
completely different in equations A.5.1.-1 and
A.5.2.-1. This may be an attempt to confuse —
at least, it is highly unprofessional.
4-127
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6.. Regarding equations A.5.1.-1 and A.5.1.-2,
it is not entirely clear what makes the water
move. p must vary with^time or space.
If conditions are "steady" then
P T3h i.
where H is the depth, hence
« a (pH )
6x 3 2.
Also £-2- *3?^) 3.
Does p vary with z and y in the model, pre-
sumably asfl"0? If not, the water will not
move due to the steady-state assumption
). Also, it is likely that near
the critical flow section
a" f£ * C 3F
hence, the dynamics must also include terms
like
tS.
5.
This is not made clear in equation A.5.1.-2,
but does appear to be in equation A.5.1.-6.
4-128
-------
regarding equation A.5.1.-2, the term
has been included in spite of
the fact it is likely small; while
wmcM is not necessarily
small, has been neglected. The nature of
dp/ax
the terra H is not outlinednor is the value
of the normalizing parameter.
Is kVjpdo? Is
f^*3rS.r>,")df 'fiVa'43 ?
Finally, note that equation A.5.1.2 is in-
correct insofar as STracy should be
used.
Regarding equation A.5.1.-3, the mass con-
servation equation shown is correct,, provid-
ing ^ is constant. It has been shown that
jx* ,y) for equation A.5.1.2 to be meaningful.
Hence, equation A.5.1.-3 is deficient.
This heat conservation equation is quite in-
correct. Surprisingly, a correct form of
this e^uoj:ion is given as equation A.5.2.-8
in the next section. In terms of this coordin-
ate system a correct form of equation A.5.1.-4
is given as
fl+ U.|I ~ Vai , K, £r + .y, $
7*
where So sources
sinks -
4-129
-------
The effect of averaging over a tidal cycle'
an increase in , usually. Note that in
equation A.5.1.-4 all the source, sink, and
mixing terms are missing. In the assumption
it is stated that there is a "steady-state
source flow" » and "constant heat
loss rate" . These are not in
equation A.5.L.-4. Further, since dispersive
transport is not included in this elation
(yet is large by virtue of the temporal
averaging), the transport relations are likely
to be quite erroneous.
Continuing, note that equation A.5.1.-9, which
is supposed to be just an integrated form of
equation A.5.1.-4, does contain a sink term!
s
Hence, they are not the same at all. Further,
a second sink results from entrainment:
is to make fiil/dtsO, and make 0**"hmuch
smaller. These reductions are reflected in
from equation A.5.1.-7. Then
8
9.
c>6T _ K6T . (j^
10.
-6-
4-130
-------
Recall (j ££ 4 11.
^Equation A.5.1.-4.}
It is easy Co see in this format that
equation A.5.1.-9 is not derived from
eqn A.5.1.-4. Further, note that the
h«at flux in the term
or
n#
in equation 11 appears to depend on the
temperature difference between the atmos-
phere and the upper layer, rather than
between the two layers of water.
Returning to eqns. A.5.L.-5 through A.5.1.-8
these are, similarly, not equivalent to
equation A.5.1.-2. The equations appear to
have been vertically integrated within each
layer. Since the tide essentially varies as
14 ^ W* Sihoj-V "+ ^
12.
so that H(x) - H (x) after averaging over
a tidal cycle, it is not at all clear what
the relative value of the term
is with respect to the baroclinic term
C" a'
dx 3 •
k,3aH 13
^ 4-131
-------
then the momentum and heat equations cannot
be run separately, as will be shown presently.
In this case an incorrect application has been
made. These velocities must be driven in part
* / o/ve.
yet no data showing p(x,y) is pre-
sented .
12. Similar comments can be made for the radial
flow case. Compared to baroclinic pressure
gradients far from the source, what is the
relative value of ^
dr
Also, why has it been assumed that aT/ap
, etc. can be neglected?
I.e.. why is there no azimuthal variation?
No data to substantiate this assumption are
Included.
13. In Paragraph 1, p. A.5.1.-5, the terms
» Ug are previously undefined; and art
presumably Ux , U2 .
As noted earlier, the reference to Lean And
Willock is obscure.
Equation A.5.1.-10 can be transposed to
ar C.QttS'V
14-
where Ty" " I 15•
4-132
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Not having the reference quoted avail-
able, it is noted that the exponent of fH±
for several studies, has varied between-1 and
-1.5. (Turner, Buoyancy Effects In Fluids.
1973).
Referring to equation A.5.1.-2, V is the vert-
ical velocity. The definition for the densi-
metric Froude number provided is
V
F -= rd =
16,
where h is previously undefined. This equa-
tion would lead to erroneous results in the
model, particularly after vertical averaging
has removed V (equation A.5.1.-5). It is
proposed that the model should use
U
5*
/gdL
'iCf.*) 9
Since
K,
17
*r£-f
18.
It appears that p refers to the density of the
warm water. This has been used to normalize
§' 1x1
„/ _ a*t
a 8f
19.
4-133
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, above on p. A.5.1.-5. Usually, the
ambient or a mean, is used for normalizing
g'in these studies.
17. On p. A.5.1.-6, the reference to the labora-
tory flows cited is not given. Neither are
data showing the densimetric Froude numbers
in the canal. "The applicability of the model
and reference are not demonstrated, therefore,
*18.. .A rather serious deficiency may lie in the com-
ment "Equation A.5.1.-9 is solved independent-
ly after the parameters h^ and T are known
at finite intervals", p. A.5.1.-6. Note that
equations A.5.1.-5 are driven by the terms
-hi §*.' - U4L
a ax. 3
Now, it is hypothesized that, over the depth
and over a tidal cycle,
5!L
20.
so, hi and Ui are driven by both terms.
Now, 8 J? .21.
p' const. 22,
° T
¦ const. T> - 23
4-134
-------
Hence, eqn A.5.1.-5 can be written
or 0| k, ^ &T- - X&T _^ ^-y
6x PCo
^ 10.
It is patently obvious that
equation A.5.1.-9 (or, equivalently,
eqn.10) cannot be solved independently
of equation 24, because the output of
equation A.5.1.-9, i.e., T(X) is needed
to drive equation 24 (i.e., *ArAx ap-
pears in both equations) if baroclinic
pressure terms are important. No data are
presented to indicate that they are not.
Hence, equation A.5.1.-9 cannot be run in-
dependently of equation A.5.1.-5. The
model is, therefore, likely inherently in-
correct.
'19^. It is surmised that equation A.5.1.-11 is
a solution to equation 10 without the term
(The problem of defining A T
was mentioned in the text after eqn .10;
this appears to be one way to obviate it).
Note that Ul in equation A.5.1.-11 is un-
Recall » - KaT A.5.1.9
4-135
-------
defined according to the list given below
it in the text. Since Q » + Q2 »
presumably, equation A.5.1.-11 is incor-
rect.
A. Comments On The Field Calibration - Section A.5.1.-3.
1. Field data were not found in the Demon-
stration, nor were any supplied to us. Use of
a model such as the one presented in Section
A.5.1.-2 would be valid only for a clearly
stratified flow which separated from the bottom
within the discharge canal. The effects of tidal
agitation tend to reduce stratification. Since
tidal effects were removed from the model it
needs to be clearly demonstrated that a strongly
stratified flow, Indeed, exists in the field.
2. There is obviously no atmospheric loss of dye,
thus, the term K in equations A.5.1.-9, A.5.1.-9'
A.5.1.-11, and A»5.1*-ll/equals 0. Hence, the
most that can be done with these data is to find
ue. However, it is shown earlier in equation 11
that Ue is keyed to temperature differences between
the upper layer and the atmosphere, and not the dif-
ferences between the temperatures of the two water
layers in the model through the term —
4-136
-------
Hence, the dye tests cannot be used to cali-
brate equation 11. If equation 11 is in error, then
dye data could be used to find Ue, but the results
would be aliased by heat losses to the atmosphere
which the dye measurements would not detect. This
is probably one (of several) reasons why the model
predicts higher temperatures than the field data in
Figure A*5.1.-l, particularly in distant regions
where atmospheric cooling is significant with re-
spect to cumulative dilution by entrainment. Other
causes of the large discrepancy could include ne-
glect of dispersive miximg and transport, and lack
of strongly stratified flow.
Finally, the discussion of "radial angles"
is quite confusing. In a radial coordinate
system the angular dependence (i.e., azimuthal)
is completely separate from the radial dependence
in these analyses. As noted previously, there is
no azimuthal dependence given in equations
A.5.1.-51 through A.5.1.-9'. Hence for this
model to be valid
4-137
-------
r C>"%y3 O
Thus, a "final angle ... of 6^' implies separ-
ated flow and angular dependence.
B. Summary Of The Near-Field Modeling
The near-field modeling can be criticized at
several levels —
1. As presented, and assuming no typographical, or
other errors, most of the equations are incorrect.
2. Assuming that there are some typographical and
other errors, and giving reasonable benefits of
doubt, the major probletns with this model appear
to be the removal of the tidal barbtropic pressure
and velocity terms, and assumption that the baro-
clinic pressure field can be generated independent-
ly of a temperature field simulation.
3. Field data to substantiate use of a 2-layer strongly
stratified laterally-averaged model in the approp-
riate densimetric Froude range are missing.
4. Use of a conservative tracer to calibrate a non-
conservative one.
5. (Expected) poor fit of model results to field data.
4-138
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In conclusion, we are not prepared to accept the
methodology and results of the near-field modeling as
presented.
Far-Field Modeling
A. General Comments
Some adjustments have been made of the far-fieId
modeling in response to our comments. However, the
basis of the approach is essentially unchanged.
B. Comments On Section A.5.2.1.2. (Appendix 5)
As was noted in the near-field.modeling section,
the coordinate system and symbols are completely dif-
ferent in Section A.5.2. than in Section A.5.1. Unless
the procedure is a somewhat transparent effort to con-
fuse, this change appears unnecessary to us.
The equations A.5.2.-1 through 7 are essentially
correct, in some contrast to the previous Section. Not
all terms are defined, ps for instance, and we
are somewhat dubious that it was included in the calcu-
lations), and the terms h and *7 are somewhat incor-
rectly defined. Nonetheless, the validity of the equa-
tions and of the model for Tampa Bay is accepted.
C. Comments On Section A.5.2.1.3.
Our objections to the grid outlined in Figure
A.5.2.-1 were outlined in previous reports. For hydro-
4-139
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dynamic simulations it is probably adequate for gross
circulation simulations of Tampa Bay, with the excep-
tion of Old Tampa Bay where the normal boundaries
exerted by the causeways are missing. In our meeting
last November we agreed that the grid would suffice if
net advection were essentially zero in the Bay, and if
the tide at the Weedon Island area were approximately
correct.
The goals of the model CAFE-1 are made more ex-
plicit in Section A.5.2.1.3. The references to Wang
(1978) are correct, but somewhat inapplicable. The
point we tried to make in our previous discussions is
that somewhat more stringent requirements are placed
upon grid geometry if CAFE-1 — DISPER-1 are to be
run together, than if CAFE-1 is to be run alone. These
hinge on stability and will be reiterated anon.
Since the goal, admittedly, is dispersion modeling,
an appropriate reference is Wang, et al» - (1978)*" in
which inset grids were used in conjunction with CAFE-1
for DISPER-1 modeling, as we recommended. The scale of
the insets was considerably less than a kilometer.
^Wang, J. D., et al. Canal Discharges Into South Bls-
cavne Bay. Rosenthiel School Of Marine And Atmospheric
Science, University Of Miami, Miami, Florida, February
28,.1978.
4-140
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With regard to Dr. Johnson's letter of September
16, 1980 (quoted below for convenience), some comment
is made.
"1. Check the implications of the net flux cal-
culations #
This item arose as a point of discussion
because Figure 11A in the Prospectus indicat-
ed substantial net velocities out of the
mouth of Tampa Bay. This was due to the
method by which the net velocities were cal-
culated, i.e., by averaging velocities
through the tidal cycle. Net velocity at a
point is recomputed by a) averaging fluxes
throughout the tidal cycle to obtain the net
flux, and b) dividing the net flux by the
average water depth. Net velocities com-
puted by this method are shown in Figure 1
and are presented in Section 3.1.4 of the
316 Demonstration. Figure 1 shows that there
are no large net velocities into or out of the
Bay".
Since^net advective fluxes into and out of a Bay
with no appreciable river inflows indicates the impos-
sible situation of creation of mass, and since they
would greatly affect net transport, we were concerned
about the net advective fluxess in the original report.
Several points of interest still linger, in view of the
above quotation. First, in reference to the definition
of ^ > on p. A.5.2.-3 and above, it is essential
that the consultant realize that the c^S are unit dis-
charges, or perhaps, unit advective fluxes. Since the
net advective flux into Tampa Bay is close to zero,
most transport, thereforet accrues across the open
boundary and into the Bay by dispersive fluxes. (This
is the essential reason we do not accept as evident the
4-141
-------
contention that large values of the dispersion coef-
ficient are conservative -- but more on this anon).
Some depth-aliasing will result if velocities, rather
than unit discharges, are used in CAFE-1 to compute
tidal net values, but these are not usually large.
Of more concern to .us is the use of the averaging
procedure itself to determine a net advective flux.
The wording in the quotation above tends to imply the
algorithm (see-wafp^ was used to find the "average
fluxes". Actually, there: is no need to average at all
to find a net flux — a simple vector sum is approp-
riate ; viz: n
% * £ a.
where unit discharges in the x,y directions,
respectively, and overbars imply net quantities, as de-
fined.
Figure 1 in the quotation above presumably refers
to Figure 3.1.-6 in the Demonstration. While the mag-
nitudes of the flows are questionable in light of the
differences between equations 1 and 2, the general pat-
tern of the circulation appears reasonable, with the
exception of Old Tampa Bay, of course•
D. Comments On Section A.5.2.1.4.
Problems in calibration and verification were raised
previously. These are^addressed in Section A.5.2.1.4,
4-142
-------
V etc-nj
M*l
* *.
m*i
4-143
-------
and in a portion of Dr. Johnson's letter of September
16th. (Included below for convenience).
Try to improve the current prediction near
Weed on Island.
The comparison of velocities between the
CAFE model predictions and the USGS field
data as presented in the Prospectus (Oct-
ober, 1979, Table 1) was acceptable at all
locations except at Weedon Island. This
comparison has been improved by adjustment
of the bottom friction coefficient so that
only a 0.01 m/sec difference exists between
model and field results at Weedon Island.
The complete calibration process for the
model is discussed in Sectiofc A.5.2.1.4 of
Appendix 5 in the 316 Demonstration."
Justify the use of eddy coefficients of 500
m^/sec.
The eddy viscosity parameter cannot be inter-J
preted wholly in a physical sense and is pri-
marily useful as a stabilizing influence for
the numerical computation. This was confirmed
by consultation with those responsible for the
model and by a sensitivity study in which the
value of the eddy viscosity coefficient was
varied. With an' eddy viscosity of 50m2/sec,
the calculation was unstable.
However, with an eddy viscosity of 200 m2/sec,
the solution was stable and the results ob-
tained weire identical to those obtained with
an eddy viscosity of 500 2/sec."
It may be recalled that we were particularly con-
cerned about poor agreement in tidal phases, and surmised
that this might be due to large eddy viscosity coeffic-
ients , particularly in view of the fact that the coarse-
ness of the grid tended to suggest that large eddy vis-
cosity values would be needed to make it stable. The
values of the eddy viscosities used were not given in the
"2.
"7.
4-144
-------
initial Demonstration draft, but we were told in our
meeting of last November that values of 500 m^/s had
been used. Since turbulence theory tends to require
that the dispersion and the eddy viscosity coefficients
should be about the same size, and since the eddy vis-
cosity tends to affect tidal phases, we felt that a
great deal had been sacrificed in order to stabilize
the grid, and suggested that another be developed.
The data presented in Table A.5.2.-1 tend to show
good agreement with the USGS data and poor agreement with
the Aquatec data, particularly in the area, of interest
near Big Bend. Certainly, the Weedon Island problem ap-
pears to be solved. Phase information is not provided
in this Table, however, and this is fully half the solu-
tion to the wave equation, as well as^the portion that
gave us the most concern previously. In light of the
high eddy viscosity coefficients used, we cannot pass an
opinion on the validity of the model calibration until
phase information is presented.
With respect to the comments regarding the sensiti-
vity study in Section 9 of Dr. Johnson's letter, the con-
clusion seems credible, although the results of the sensit-
ivity test are not given. However, it would be more
germane to compare coefficients in the order of magni-
A
tude of the dispersion coefficients (8-30 m /s vs.
200-500 m^/s).
4-145
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Comments On St.ction A.5.2.2.2. (DISFER-1).
Equation A.5.2.-8 is correctly stated, in contrast
to equation A.5.1.-4. Note that this equation is linear
in C, has arbitrary values of dispersion coefficients
(unlike the eddy viscosities which can be roughly estimat-
ed by shear terms in the momentum equations and subgrid
eddy-scale theories), and that a non-conservative grad-
ient sink term for temperature is not included (if C - T).
One was apparently devised, however.
Usually, in referring to CAFE-DISPER, Eij are used „
for eddy viscosities, and Dij for dispersion coefficients
(in contrast to equations A.5.2.-9, 10). We will use
this notation here to avoid confusion.
Finally, note that yet another set of mathematical
symbols is used in equation A.5.2.-8 than in equation
A.5.2.-1. The need for such frequent changes is certain-
ly not evident to us.
Comments On Section A.5.2.2.3.
1. Regarding the so-called isometric coefficients,
it can be seen by substituting equations A.5.2.-9
and 10 into equation A.5.2.-8, and reversing the
order of differentiation, that the best values for
an isometric diffusion matrix are Bxy» Eyx* *
4-146
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2. We have been through Che issue of appropriate
dispersion coefficients before, particularly
in our recent negotiations with Seminole re-
garding the modeling of the St. Johns River.
In general, it was decided that turbulence
theories require that the turbulent Schmidt
number be of first order at least, and prefer-
ably between 1 and 2. For the same grid « this
would require
Eii ¦ 1 to 2 1
EII
(Further, as a result of the Seminole ne-
gotiations a procedure for determination of
appropriate minimum dispersion conditions was
proposed1•) .
Now, a grid also inherently involves spatial
integration transversely, so a so-called S.G.S.
eddy coefficient must be used which accounts for
some transverse dispersion, in addition to
Taylor-Elder dispersion. Hence, Eii and DJU,
can be larger than the turbulent eddy viscosity
and diffusivity. However, they should not be
much larger if real-time advection is maintained.
^•'Graham, D.S., Appropriate Minimum Dispersion
Criteria For Tidal Rivers:, Proc. of ASCE
Hydraulics And Energy Div. Spec. Conf. On
Conservation And Utilization Of Energy Re-
sources, Aug. 8-11, 1979, San Francisco, CA,
pp. 130-137.
i-li7
-------
(again, the comments regarding the near-field model
are germane). Finally, the grid should not be much
coarser than 1/2 to 1/3 times the characteristic
len^hscale of the phenomenon being studied, in this
case, a thermal plume.
Accepting, as we surmised, a real dispersion co-
efficient of about 1-5 m^/s, (actually 8 m^ /s it
appears), plus an SGS increment of perhaps 10-20 tn^/s
for a grid as coarse as Figure A.5.2.-1, a value of
Dii of 20-40 m^/s might be appropriate for this grid
scale. (An inset grid which would be stable at
5-10 m^/s would be preferable).. Hence, we are not
surprised by point No. 6 in Dr. Johnson's letter
(below)1 that the grid was marginally stable at
30 m^/s and unstable at 8 m^/s. Indeed, a 30 m^/s
is likely an appropriate value for the grid being
used.
If we elect to use a higher dispersion
coefficient than is justified by the dye
survey, demonstrate that the results are
conservative.
The dispersion coefficient value used in
the thermal discharge study was 8 xnr/sec,
the same value obtained in the field cali-
bration. For the meroplankton entrainment
study, a higher dispersion coefficient of
30 m^/sec was used in order to improve num-
erical stability. This value was conserva-
tive- because a higher dispersion, coefficient
will result in a greater degree of entrain-
ment of meroplankton."
4-148
-------
Our objections concerned the following:
a) that
Eii = 500 _ i .
DiT 3TT 16 •6 1 2.
which leads us to surmise that the advective
inputs to equation A.5.2.-8 are wrong.
b) That the lengthscale of the grid was
longer than the phenomena being studied, so
that their characteristics would be aliased,
and
c) That the two models (near-field and
farfield) would be difficult to link.
We still have these reservations.
Further, no comparisons of DISPER-1 cali-
bration on verification output are given in
either the Demonstration, Appendix 5, or Dr.
Johnson's letters.
Finally, referring, again, to Point 6 of
Dr. Johnson's letter, it is not demonstrated
that use of high dispersion coefficients is
conservative. A demonstration would consist
of an analytic proof, or comparisons of com-
puter simulations with different values of
Dii. We can point out that the concentrations
4-149
-------
of any constituent are dependent upon the
advective and dispersive fluxes. Figure
3.1.-6 shows net advectioii; the net
app«cu-
advective fluxesAto be small. Hence, the
transport in Tampa Bay is large dependent
upon dispersive fluxes. These are increased
by raising Dii. Impact would be proportional
to _ Dij
and hence, ^ for Dij » constant.
Greater mixing and transport would tend to
reduce , and hence, ^ C/^*J >
thereby increasing impact.
G. Comments On Section A.5.2.2.4.
1. No model results are provided; hence, no opinion
can be offered.
2. We are surprised that the model was stable for
thermal simulations at 8 tn^/s, but not stable at
this level for meroplankton simulations.
3. Charcteristics in the area of impact where the
near-field and far-field models meet is not clear.
Both models tend to be most accurate in regions
of lesser interest — i.e.. the middle of the Bay
or well within the mixing zone. The zone of major
4-150
-------
incremental impact is the adjacent portion
of Hillsborough Bay. An inset grid for dis-
persion studies would be helpful here.
4. It is not made explicitly clear how a know-
ledge of circulation and mixing processes was
tied to biological response. (Point 4 of Dr.
Johnson's letter). This will be discussed in
a separate review.
H. Simnarv Of Far-Field Modeling
The problem with the net advective fluxes appears
to have been solved, as has tidal amplitudes near Weedon
Island. Otherwise, the majority of our comments about
the deficiencies of the far-field study is still applic-
able. Specifically, we recommend detailed dispersion
modeling near the plant discharge and relating the re-
sults to biological response.
4-151
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SIERRA CLUB
FLORIDA CHAPTER
1601 NW 35 way
Gaineville, FL 32605
March 28, 1981
Mr. H.S. Oven, Jr.
Power Plant Siting Administrator
Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 323OI
Dear Bucks
Enclosed are the comments made by our consultant,
Mr. D.S. Graham on Amendment 5 to the TECO application.
Yours truly
barney i». uapenarx
Power Plant Siting Committee
Chairman
cc: Mr. John Ramill, TECO
Mr. H. Zeller, EPA
Ms. Laurie Rask, Tampa Group Sierra Club
-------
COMMENTS ON AMENDMENT 5 OF THE TECO APPLICATION
by the Sierra Club
We are encouraged to see more detailed analyses of the
fate of potentially toxic waste streams that may enter Tampa
Bay. We had expressed concern about this previously. Some
observations are ^made here with respect to the various
responses by the Applicant in Amendment 5*
Question 1.
The reply to this question rests too heavily upon untested
assumptions. Noting in the reply to question five that the
velocities are quite low, the canal quite deep, and the length
short, it is not immediately evident that complete mixture will
occur. While this may be the case, some calculations to support
this assumption would be helpful.
Question 2.
No comment.
Question
These data are quite interesting. Evidently ambient con-
ditions exceed FWQS and it is therefore not clear how increasing
the level of excess, even slightly, will improve the situation.
Nevertheless the proposed POD is likely the best, and certainly
better than local streams or groundwater. Ambient water quality
may very well preclude future plant siting on upper Tampa Bay.
The data presented presumably assume complete mixture to
occur. As in question 1, this should be demonstrated with a
few calculations or measurements. Further, heavy metals often
4-153
-------
tend to associate with sediments rather than mix freely within
the water column. Is this likely here, and is there a problem
with heavy metal concentration in the sediments near the discharge
canal at present?
In general, the Applicant's proposed management of waste
streams is well thought out and acceptable to us.
Questions 4-9.
No comment.
Question 10.
We have had some difficulty locating Table 5.2-4 of the
SCA. It would be appreciated if this were provided, or if the
calculations were shown. This again returns to the estimate
of appropriate dispersion coefficients for the canal.
Since releases are for 2 hours, the utility of 96 hour
LC^q's is dubious.
Since the discharge is into saltwater, we would have no
problem with a mixing zone for FAC provided it did not extend
beyond the discharge canal.
4-154
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c/o B. Capehart
Gainesville ChapC,
Sierra Club
July 23, 1981
Mr. Hamilton S. Oven, Jr.
Administrator, Power Plant Siting
Section
OER
Twin Towers Office Building
2600 Blair Stone Road
Tallahessee, FL 32301
Dear Mr. Oven:
Barney Capehart sent me replies from TECO regarding my comments on
the Big Bend - Unit No. 4 316 Demonstration. I looked them over briefly a
month or two ago, but have not had a chance to reply until now.
The Applicant has obviously endeavored to answer our queries to a
reasonably detailed degree and at a technically appropriate level.
I have read thru the replies and examined them in detail. After
doing so I do not see any need to go thru a step-by-step discussion once
again. Any person familiar with this particular branch of science would be
able to see the points we were trying to make and the degree to which the
Applicant has addressed them. In general, I think most of our criticisims
remain valid. These issues have now been raised and clarified, and I think
that you, and the other regulators, now stand in a reasonably good position to
make a decision. On the basis of the information presented we are not_
convinced that negligible environmental impact has been conclusively proven"
and would therefore encourage you to deny the Application for once - thru
discharge to Tampa Bay at this time.
Thank you for the opportunity to have participated on this process.
Yours sincerely,
D. S. Graham
OSG: 1.35
4-155
-------
1601 N.W. 35th Way
Gainesville, FL 32605
December 13, 1980
Honorable Robert Mann, Chairman
Florida Public Service Commission
Fletcher Building
Tallahassee, FL 32304
Dear Chairman Mann:
I will not be able to attend the PSC final need hearing
for the TECO Big Bend 4 unit. However, I have a number of con-
cerns that I would like to express, and I hope you will address
these at the hearing.
S.B. 1052 Section 366.86 states that in making its deter-
mination of need, the PSC shall take into account "whether the
proposed plant is the most cost effective alternative available."
And additionally "The. Commission shall also expressly consider
the conservation measures taken by or reasonably available to
the applicant or its members which might mitigate the need for
the plant...."
Neither the TECO site certification application nor the PSC
preliminary report of October 15 thoroughly identify or evaluate
the conservation measures reasonably available to TECO. Without
this identification and evaluation, there certainly cannot be a
judgement that building the plant is the most cost-effective al-
ternative. The alternatives considered, and quickly dismissed,
are all central station generation alternatives. There is little
realistic attempt to consider decentralized alternatives except
for cogeneration. The TECO answers to the PSC interrogatories
also fail to explore conservation and decentralized solar proj-
ects .
The logic behind looking at central station generation seems
to be that if one single source of 400MW cannot be found, then
there is no alternative to building the new plant. However, a
oombination of alternatives such as cogeneration, conservation
and solar water heaters could very well be enough to replace the
400MW of coal capacity. Unless this combination or other com-
binations are given a fair examination, there is no reason to be-
lieve that building the 400I1W coal plant is truly the most cost-
effective alternative. In addition, the combination of cogenera-
tion, conservation and solar water heaters could supply some
fraction of the 400MW capacity at a more cost-effective invest-
ment level. This possibility has been ignored completely.
Building the 400MW coal plant is not the only way to reduce
our dependence on imported (into Florida) oil. Cogeneration,
conservation and solar water, heaters have the same effect.
Whether a KWH of oil generation is replaced by coal or elimin-
ated because of increased energy use efficiency, the result is
the same—that oil is not used. Therefore, the question should
be--what is the most cost-effoctive investment for a utility to
make to eliminate its dependence on oil?
4-156
-------
Testimony during the Conservation Goals hearings absolutely
proved that conservation programs in Florida, as well as other
states* provide a less costly way to satisfy customer demands up
to some level. Clearly, all power needs cannot be supplied by
savings from more efficient uses. However, until we have imple—
mented this less costly method, it makes no sense to go forward
with a more costly program in total, or in part.
In particular, my revised testimony of October 20, 1980 for
the Inter Agency Work Group described cost-effective programs in-
volving replacing inefficient refrigerators and air conditioners
with high efficiency models, and installing heat pumps and solar
water heaters. Tq my knowledge, TECO has not examined such pro-
grams in light of satisfying part, or all, of the 400MW of the
proposed Big Bend 4.
The legislative revisions to the Power Plant Siting Act
contained in SB1052 speak clearly and forcefully to the require-
ment to evaluate all conservation programs reasonably available
to the applicant. I believe TECO has failed to do this, and I
implore you to require them to meet the intent and letter of
this law.
Another matter of concern to me is the possible inequity to
present ratepayers from a decision to build Big Bend 4 if found
by the PSC to be the most cost-effective alternative. The eco-
nomics of a cost-benefit decision do not address the question of
who pays the cost versus who gets the benefits. Specifically,
my concern is that present ratepayers may well end up paying
significantly higher rates so that future customers can pay sig-
nificantly lower rates. The fact that the total cost to both
groups is lower if the plant is built should not be the sole de-
ciding factor. Why should present customers pay more now, and
in the future, so new customers can pay less? What is the equity
and fairness of this decision? This is an example of disaggre-
gated costs and benefits where the group that pays most of the
cost (the present ratepayers) is different from the group (the
new customers) that gets most of the benefits. if the project
indeed has greater benefits than costs, there still must be some
other decision made to allow for equity to present ratepayers.
This decision must be to have a future reduction for present cus-
tomers so that they do not subsidize new customers.
In the past there was no need to consider such a factor,
since new power plants were less costly than old plants, and all
customers benefitted from this expansion. However, our present
situation is such that new power plants are far more costly than
old plants, and all old customers are penalized by having to pay
the costs of expansion. Again, equity requires that some rate
structure change be initiated to prevent present customers from
subsidizing new customers.
One possible rate structure chanqe to eliminate the subsidy
is to establish a "front end fee" or "capital facilities charge."
This is already done for water and sewer services in areas of
4-157
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the state, and is an accepted method to charge new customers
their fair share. A similar approach should not be difficult
to implement for electric service, I'm sure there are also
other acceptable rate structures which could be applied in this
instance to accomplish customer equity,
I know there are many issues the PSC will consider when
the final hearing takes place, and I hope that the questions I
have raised will be thoroughly explored in the process.
Thank you for considering my input.
cc: Honorable Joseph Cresse
Honorable Gerald Gunter
Honorable John Marks
Honorable William Mayo
Mr. Joe Jenkins, PSC
Mr. Hamilton Oven, DER
Mr. Jack Shreve, Public Counsel
Mr. H. Zeller, EPA
Mr. H.L. Culbreath, TECO
Sincerely,
KAU tV
Barney LY Capehart
4-158
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SIERRA CLUB
FLORIDA CHAPTER
1601 NW 35 Way
Gainesville, FL J2605
February 1, 1981
Mr. Dario Dal Santo
EIS Branch
U.S. Environmental Protection Agency
3^5 Courtland St. NE
Atlanta, GA 303^5
Dear Mr. Dal Santo:
Thank you very much for taking the time to discuss with
me the requirements for the Draft EIS on Tampa Electric Company's
Big Bend 4 Unit. I know you have many projects to work on and
I appreciate your interest in my concerns. As I stressed in our
telephone conversation, I am greatly disturbed to learn that
the EPA has not included consideration of conservation and renew-
able sources as one of the alternatives to be analyzed in the EIS-
on TECO's Big Bend ^ Unit. This alternative should have been
much more thorougly examined at the state level by the Florida
Public Service Commission, but it was not. Therefore, it is
critical that the EPA examination of alternatives include a
rigorous analysis of the conservation/renewable sources alterna-
tive to power plant construction.
The failure of the Florida PSC to require TECO to fully
study the alternative of conservation and use of renewable sources
is very surprising since the FPSC has just finished a process of
setting energy conservation goals for all state utilities. The
Florida legislature passed a bill in 1980 which required the PSC
to set goals for electric utilities which would reduce growth
rates in the consumption and the weather sensitive peak use of
electricity. The PSC goals adopted do measurably reduce these
growth rates. The FPSC projected demand growth of an annual rate
of ^.5^ percent is to be reduced to 2.31 percent. The growth rate
in energy consumption is expected to change from 4.£5 percent to
2.8 percent.
In the process of setting these goals, the FPSC held public
hearings to obtain evidence for selecting the goals. A represen-
tative of TVA testified regarding the costs and benefits of the
various conservation and renewable source projects underway in
the TVA region. A copy of that testimony is enclosed. In *
addition to numerous other witnesses, I testified in favor of
much more stringent goals. A copy of my testimony and detailed
•\
4-159
»*• ¦ ¦ • •
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calculations is enclosed. A great deal of relevant testimony-
was offered during these hearings and this information should
be available in the FPSC hearing record. Another document of
interest written by the FPSC is the first preliminary report
on the need for the TECO Big Bend ^ Unit. This draft report
stated that if the conservation goals were adopted as proposed
the Big Bend 4 plant would not be needed. Although the final
version of this preliminary report appears to hedge this con-
clusion with some additional economic information, in fact it
merely indicates that coal generation is cheaper than oil gener-
ation and does not examine economic costs and benefits of conser-
vation. A copy of the conclusion page from each report is
enclosed.
The FPSC goals hearing record and EIS's on other projects
show that there is adequate information to support conservation
and the use of renewable sources as an alternative to building
a new coal-fired power plant. In the Allen-Warner Valley Energy
System EIS, conservation and renewable sources were recommended
by EPA as the preferred alternative. With this wealth of infor-
mation in existence, it is imperative that the EIS on TECO Biff
Bond 4 include a full evaluation of these alternatives- The
CEQ guidelines for preDaration of an EIS are very specific in
terms of identifying and analyzing alternatives. UO CFR g 1502.1^
on Alternatives Including the Proposed Action states "This section
is the heart of the environmental impact statement. ...In this
section agencies shall: (a) Rigorously explore and objectively
evaluate all reasonable alternatives... (c) Include reasonable
alternatives not within the jurisdiction of the lead agency. ..."
The CEQ regulations emphasize the identification and analysis of
real alternatives, and stress that the EI analysis is to concen-
trate on alternatives, the heart of the process. In particular,
the CEQ comme~nts on" the regulations emphasize that the examination
of alternatives is a requirement that is firmly established in
the case law interpreting NEPA.
The BLM Draft EIS on the Allen-Warner Valley Energy Project
evidently relied heavily on an analysis performed by the Environ-
mental Defense Fund using a model developed by EDF economist Dr.
W.R.Z. Willey. I have included a page from an EDF newsletter
which references this report. Since EPA often uses consultants
to help in writing EIS's, it would appear reasonable to consider
contracting with EDF to perform a similar study for the TECO
Big Bend *+ plant. EPA's role as a public agency should preclude
passing the burden of analyzing reasonable alternatives to citi-
zens who are serving as volunteer and unpaid representatives of
the public interest. The public should have the responsibility
to determine whether the EPA analysis of alternatives is adequate
but should not be forced to do the bulk of the analysis.
4-160
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In summary, the Sierra Club requests the following
actions from EPA with respect to the EIS on Tampa Electric
Company's Big Bend ^ application:
1) that conservation/use of renewable sources be included
as one of the alternatives to be studied in the EIS process?
2) that the conservation/renewable sources alternative
receive consideration and study equal to any other alternative
as required by NEPA; and
3) that EPA use the Environmental Defense Fund-Willey
model, previously endorsed by EPA in the BLM Allen-Warner
Valley Energy System EIS process, to conduct a rigorous analysis
of the conservation/renewable sources alternative.
Thank you again for your interest in this matter. If you
have any questions about these requests, please feel free to
contact me.
Yours truly.
Barney L. Capehart
Power Plant Siting Chairman
cc (without enclosures)!
Mr. H.L. Culbreath, TECO
Mr. Robert Howard, EPA
Mr. H.S. Oven, DER
4-161
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SIERRA CLUB
FLORIDA CHAPTER-
The Florida Chapter of the Sierra. Clue is gravely concerned about the
ECONOMIC AND ENVIRONMENTAL EFFECTS OF THE PRESENT-RUSH TO BUILD MASSIVE .
NEW COAL-FIRED ELECTRICAL POWER" PLANTS IN THE STATE OF FLORIDA..
Several recent studies such as the uffice of Technology Assessment's
"Direct Use of Coal% and thb University of Florida s "Coal.Burning
Issues" and. Impacts, of Increased.Coal Use in .Fu^uta" have, identified,
MANY MAJOR. PROBLEMS' INVOLVED WIT*# BURNING LARGE? QUANTITIES OF COAL*
IE ARE DEEPLY CONCERNED THAT THE PRESENT POLICY QF MASSIVE COAL USE IN.
-LOR IDA HAS- EMERGE!? WITHOUT Ah COMPLETE!". REVIEW BY RESPONSIBLE STATE AND
FEDERAL AGENCIES AND. THE: PUBLIC. IN GENERAL, . SUCH A PROGRAM" HAS TREMEN-
DOUS PUBLIC POLICY IMPLICATIONS THAT. APPEAR. TO HAVE BEEN TOTALLY IGNORED,
Significant problems of coal us^ smvqlve:
.AIR- POLLUTION .RADIOACTIVITY IN COAL WASTES
.WATEfc POLLUTION ^VISIBILITY REDUCTION
, COAL AStt DISPOSAL »ACEB RAIN.
.COAL SLUDGE DISPOSAL *COAL; TRANSPORTATION HAZARDS
Use OF COAL. IS pull OWIJ^ OPTION IN* ANSWERING THE PROBLEMS'QF
HOLDING COSTS# OF- ELECTWIClTr LQWEI* WHILB REDUCING OUR" DEPENDENCE ON
IMPORTED QIL~ (TTHER ALTERNATIVES ARB; AVAILABLE WHICH ARE PROBABLY: .
CHEAPER AND ARE UNDENIABLY LESST DEGRADING;'TO OUR ENVIRONMENT. THE*
STATE OF FLORIDA REtrES-HEAVILY ON ITS IMAGE OF CLEAN* AIR AND CLEAM^
WATER TO ATTRACT• TOllRf STS*' NEVf RESIDENTS AND NEW INDUSTRY, WE CANNOT
AFFORD. Ta FOUL OUR own ENVIRQNMEWfcVOTH. a POORLY JUSTIFIED POLICf TO
BURft MASSIVE AHQUNTSGF-COAL* -
SOMfi? or THS AtT5HSWlPiSUl?PUE^aF'N^niRAli^GAS-
.DIRECl> USff Of* Ol£fAra*S/«Sf
. CQItSERVATIQfl^THRGUGHE INCREASED^ EFFZCfENC^GFt USE
;US^O#OQ6ENERA¥lQti. 4
.~SaOf#SCtAR/REUEWABLgLENEFtS* SOURCES
The Florida ~m£ts& qb: sierrackjb». ha$:previously expressed our grave
CONCERN- TO- TH8' E?iCSEGAREtt£N^fHBf APPROVAL CJP^THB-TECCy BES BEND" COAL*
FIRED POWERS PCJWnrt^'iIUE^TOfeTH&EXTREMEt\f SERIOUS- ECONOMIC AND ENVIRON-
MENTAL PROBLEMST. POSSFBt^'FROPtBUHLMNfii NEliir COAL; FIREH POWER. PLANTS*. WE
REQUESTED TH^r^Tt^EPAaa
i
It tfkAiS^^&^E^XSt6fU^SlXtK Qf^'RENEWABLE^. SOURCES AS ONE OF
THBfc AKTEENATIVE^TOh B&^SIUDiei lit THE, EISP PROCESS;
-------
THAT THE CONSERVATION/RENEWABLE SOURCES ALTERNATIVE RECEIVE
CONSIDERATION AND STUDY EQUAL TO ANY OTHER ALTERNATIVE AS
REQUIRED BY NEPA; AND
5* THAT EPA USE THE ENVIRONMENTAL DEFENSE FUND-WILLEY MODEL,
PREVIOUSLY ENDORSED BY EPA IN THE BLM ALLEN-WARNER VALLEY
ENERGY SYSTEM EIS PROCESS TO" CONDUCT A RIGOROUS ANALYSIS
OF THE._CQMSERVA.TiaN/RENEWABLE SOURCES ALTERNATIVE*
IHF d,WT EIS DISCUSSION OF CONSERVATION AND RENEWABLE ENERGY" SOURCES
AS AN, ALTERNATIVE IS LIMITED-TO .THE. FLORIDA PSC REVIEW WITH RESPECT
1° THE RECENTLY EffACTEU STATE ELECTRICAL ENERGY CONSERVATION GOALS.
THUS, THE EPA HAS TOTALLY ABROGATED ITS.RESPONSIBILITY FOR CONDUCTING
A THOROUGH INVESTIGATION OF CONSERVATION: ANB RENEWABLE ENERGY SOURCES-
AS A VIABLE ALTERtfATrVE,/ THE FLORIDA PSO REVIEW, OF THE NEED QUESTION:
NEVER ADDRESSED. THE POSSIBILITY THAT; A CONSERVATION/RENEWABLES PROGRAff
INCREASED* SCOPE COULB TOTALLY ELIWFNATE THE NEED FOR: THE TECO BIG
send 4 planth The conservation goals set by the Florida psc are admir-
m that a state policy of conservation is promoted, BUT THE MAGNI-
TUDE OF THE GOALS IS CLEARLY FAR BELOW THE READILY' ACHIEVABLE REDUCTIONS
;?SSTBLE. USING PRESENT TECHNOLOGY* CONSERVATION PLANS SUBMITTED BY
rLQRIDA UTILITIES, INCLUDING TECO, SHOWED A WIDE ARRAY OF COST- '
WECTIVE PROGRAMS FOR REDUCING ELECTRIC ENERGY CONSUMPTION BY IMPROVING*
tND- USE EFFICIENCY ANH BY INITIATING RENEWABLE ENERGY* SOURCE PROGRAMS.
JHERE IS SIGNIFICAPCT- EXPECTATIOft TrtATAt conservation/renewable source;
fHOGRAM COULD BE a VFABLE ALTERNATIVE^ TO^THE H2S MW. HI & BEND 4 PLANT»
EDF STUDY QF THE,ALLEN-WARNER VALLEY-PROJECT INr CALIFORNIA SHOWEIE
'f.AT ALTERNATIVE SOURCES" COULD* PROVIDE MORE ENERGY: ,IN THE SAME TIMET !
SplOD, AT LOWER COSTS ANDr WITH FARp LESS ENVIRONMENTAL RISK. THE EPA
rJJQORSED THE CONCLUSIONS?! QE THAT ED& SIUDY ANQ* SUBSEQUENTLY REFUSED TO
:?ANT a CLEAN AIFI PERMIT?- FORt THp^ PROPOSED COAL .FIR9* PROJECT. SUCH A
TOTAL TErars^E^V/W Gft^- THEREFOR^BErREPLACEII HY REASONABLE
g^^RVATIQN/RENEWAB^SOt/RC^- ALTERNAFiVE^PROGRAMS. THE FAILURE OF
TO PURSUE SUCH /t snnrr IfcWZ TECa- CASEAPPEARS INnICATIVE OF EPA^S
Puv RGf'£ it* FAVOR £N€* INDUSTRIAL: EXPANSrOftREQUESIS;REGARDLESS OF THE
hvslcal. anbp EcaNaMrCrCasT^j^T^E:,CQWsut!ER,
SPEClFlCt CONSEllVATXGtNl' PRGGRAJ^WITK LARGE; POTENTIAL; FQF? THE
Cot SERVICE AREA.AREtS
Av REPLACEMEfnr.OF'PRESEfrf'REFRIGERATORS WITH?.' HIGH EFFICIENCY
models wHiat wouLif result? in* Aff average saving? of almost
IOOOkwH. PEBs.YEAaycOf* EACHt*ElESyjEPftTAL. CUSTOMER.-
Ef, '. REPLACEMENT Off. PRESENT?" ERECXRIC RESISTANCE WATER HEATERS
WFTHf SQLASt ONIT&WHIO* WOULD^'RESULT IK" AN AVERAGE SAVING OF
25Q0KWfc* PERivYEAREi-FOR^EAGti RESIDERXIAL. CUSTOMER.
UQY RFLATIVE TO. THE Blfit BENIJ % PLAWF*-WOUUX VERY LIKELY SHOW SIMILAR
?esults:The0F
4-163
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c. replacement of pre:ent central air- CONDITIONERS WTTH HIGH
EFFICIENCY UNITS WHICH WOULD RESULT IK AN AVERAGE SAVING OF
ABOUT lbOUKWH PER YEAR FOR EACH RESIDENTIAL CUSTOMER.
D. SIMILAR PROGRAMS FOR COMMERCIAL CUSTOMERS PLUS CQGENERATION
COULD RESULT IN EVEN GREATER PERCENTAGE SAVINGS IN THIS SECTOR.
Although utilities frequently- allege that they have no control over
CUSTOMERS EFFICIENCY DECISIONS, THE TRUTH IS THAT INNOVATIVE PROGRAMS
CAN- INDEED INFLUENCE APPLIANCE MARKETING STRATEGIES AS WITNESSED WHEN
UTILITIES PROMOTED ELECTRIC APPLIANCES AND ALL-ELECTRIC HOMES, FURTHER-
MORE/ THE POLICY OF HAVING PRIVATE INDUSTRY PROMOTE SOCIAL POLICIES
RATHER THAN THE GOVERNMENT APPEARS TCI BE. THE CORNERSTONE OF PRESIDENT
Reagan s philosophy, Thus* if an. epa study proved conservation to be
THE MOST COST-EFFECTIVE ALTERNATIVE# TECQ WOULD HAVE THE OPPORTUNITY
TO EMBRACE THE KEAGAN APPROACH WHOLEHEARTEDLY,
BUILDTNG A NEW COAL FIRED POWER PLANT AT &LDGO PER KW CAPACITY PROVIDES
ELECTRICITY AT A COST OF ABOUT 9 CENTS PER KWH. At THIS PRICE, MANY
PROGRAMS OF CONSERVATION# RENEWABLE SOURCES AND COGENERATION BECOME
COST-EFFECTIVE. IN ADDITION^ THE SAME OIL REDUCTION POSSIBLE FROM
BURNING COAL IS OBTAINED Br THESE CHEAPER AND CLEANER ALTERNATIVES
WHICH DQ NOT HAVE THE SEVERE ENVIRONMENTAL PROBLEMS WITH THEIR USE AS
COAL DOES*.
The VERY' PURPOSE Q£ HAVING £ REQUIREMENT FOR. EVALUATION OF ALTERNATIVES:
FOR NEW COAL FI REDS' BOWER* PfcANTS irTTHE- EIS, IS-TOMD IM IDEMXimWVAiUJ^
ADOPTING THESE. CLEANER AND CHEAPER. APPROACHES. THE EPA HAS NOT ONE*v *
FAILED IN ITS LEGAL OBLIGATIONTCT PROVIDE A THOROUGH' ANALYSES OF ALTEF?-*
NATIVES# BUT IT HAS ALSO FAILED* THE-VAST MAJORITY OF FLORIDA CITIZENS "
WHO WANT CLEANS AIR*- CLEAM WATER-AND THE LEAST EXPENSIVE APPROACH TO
SATISFYINS THEIR ENERGY SERVICE NEEDS*
The: draft Ers conclusion*- th/w "However#**»jvccQiujiNGLYconservation was
NOT CONSIDERED''TO BE Aflfc.APPROPRIATE* MANAGEMENT ALTERNATIVE- IS. COM-
PLETELY. IRRELEVANX SINCETJtfJ'. THOROUSH STMrr Ofc CONSERVATION WAS" EVER
CONDUCTED^ THB ELaRl^ SSe ^THB EP/fa^rrrHUS* THE. DRAFT EIS IS
CLEARLY ^ADEQUATE-* ANH J^-THOROUGHT STUDY 01* CQftSERVATIOPf AND RENEWABLE
ENERGY SOURCES MUST B& PERflORKEI> ANflt INCLUDE!* irt THE FINAL EIS IN
ORDER FORT IX Ta MEEF^EP/K%>JE£M^ QBUGATlGft*
In summary :theTRESPoasiBiLrt^rra identify and, study?
AL£ VI ABLE ALTERNATIVES * CAS&EWV? ZtltFS- CQORBlNATI NG COMM. V. IT.SV
ATOMIC ENERGY COMMISSIOPT IW»^.2Dt 1IG91 CIR* 1971) „ FURTHERMORE*.
EPA, HAS ALREADY ESTABLISHES A PRECEDENT FOR. STUDYING THE CONSERVATION.
ALTERNATIVE*. SEE' THP; AtLElf^WARNER VAfcLE?£ ENERGY SYSTEM EIS. It*
ADDITION. EPA.. iS' CONDUCTINfl^SUQT/T STUDY'FOR.'ANOTHER FLORIDA UTILITY ^
THE JACKSONVILLE EEECTRIC AUTHORrCfV JEiV IS* 1QG* DEPENDENT Ofi OIL
UNLIKE? TECa WHICH ALREADr-RAStSOBSTANTIAfc'COAi:- GENERATING CAPACITY.
TO PERFORM THE'STUDY FOR; JEA^WHILE,- I6N0RIN&THE ALTERNATIVES FORT TECa
APPEARS IRRESPONSIBLE*.:
The SIERRA. CLUB REITERATE3T rrsTPDRMAt REQUEST THAT EPA ADHERE TO THE
REQUIREMENTS OF THE LAV# IN? EORMULATIN© THE FINAL. EIS FOR THE. TEC® BIG
BEND $ PLANT*. FOLLOWING- WIKIMM* LEGAL-REQUIREMENTS SHOULD BE STANDARD*
AGENCY PROCEDURE. AND SHOULD NOT REQUIRE LEGAL. BATTLES FROM CITIZEN;
GROUPS TO ASSURE SUCH COMPLIANCE'-
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ATTACHMENT I
Conservation Alternative to Big Bend 4
A. Energy Output of Big Bend 4
417 MW capacity at 60% use
417,000 KW x 5256 KWH/KW = 2192 GWH
B. Residential Conservation Measures
(based on 300,000 customers)
1. Replace refrigerators by high efficiency models
Savings of 924 KWH/customer
10095 saturation of refrigerators
924x300,000 = 277 GWH
2. Replace resistance water heaters with gas models
Savings of 36OO KWH
93# saturation of electric w/h
.93x3600x300,000 = 1004 GWH
3. Replace strip heaters by gas heaters
Savings of 4800 KWH
47% saturation of strip heaters
.47x4800x300,000 = 677 GWH
4. Replace central air conditioners with high efficiency units
Savings of 2000 KWH
52.5% saturation of central a/c
.52x2000x300,000 = 315 GWH
5. Replace window air conditioners with high efficiency units
Savings of 666 KWH
32% saturation of window a/c
.32 x 666 x 300,000 = 64 GWH
Total savings 2337 GWH
C. Thus, the conservation potential is there from only the
residential sector, and this sector accounts for only 35# of
the total energy produced by TEC0.
4-165
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RESPONSES TO WRITTEN COMMENTS
RESPONSE FDA-1
Comment acknowledged.
RESPONSE SCS-1
Comment acknowledged.
RESPONSE DER-1
Errata. Corrected page is included in Chapter 2 of this FEIS.
RESPONSE PER-2
Comment acknowledged.
RESPONSE COE-1
The executive summary has been rewritten to clarify this point. See the
executive summary of this FEIS.
RESPONSE CDC-1
The Hillsborough County Mosquito Control Board (HCMCB) has been contacted
regarding potential vector habitat areas in the Tampa area in general and
the Big Bend site in particular. The HCMCB is 1
site, and TECO has worked and cooperated with the HCMCB to address potential
vector habitat areas. In the past, measure, have been
habitat potential in the spray irrigation fiel » « 3 mmint»ininr a*
These measures have included providing better **in jj vector-
low cut grass height. The HCMCB has indicated the potential for "^tor
u m area. It is anticipated these
borne impacts is minimal in the Big Bena are®*
potential problems will continue to be controlled.
RESPONSE CDC-2
The variance is for the mixing zone and is needed primarily because the
a®bient water quality in Tampa Bay exceeds the Florida Water Quality Stand-
ards (as noted in the comment). Because operation of the facility requires
u8e of Tampa Bay water, discharge of this very same water would exceed the
Standards. Analysis indicates there would be no analytically detectable
increase in the levels of these metals in the discharge canal. Under pro-
visions of the Florida Statutes, a variance for Unit 4 from the Florida
Department of Environmental Regulation's water quality standards has been
Sfanted for two years.
4-167
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RESPONSE CDC-3
The isothermal contour maps shown in Figures 3-37 and 3-38 of the DEIS serve
to illustrate in an idealized manner the aerial extent of the expected sur-
face plume relative to average temperature increases above ambient conditions.
The maps are not a realistic depiction of the plume's configuration because
the instantaneous effects of wind and tide are not considered in the computer
simulation. Infrared imagery of the actual surface plume configuration are
provided in 1977 Big Bend Station Section 316 Demonstration (TECO, 1977).
The aerial photographs demonstrate the variable nature of the surface plume
configuration relative to tide phase. In some instances, tidal forces di-
rect portions of the surface plume laterally from the point of discharge and
along the shoreline of Apollo Beach. Consequently, some mixing of the heated
effluent with embayment water occurs. Similar mixing events were also docu-
mented with aerial imagery in November 1979 by EPA surveillance of the plume.
It can be concluded that the mixing of heated effluent with embayment water
will be a continuing feature of the surface plume. Based on data presented in
the DEIS and supporting resource documents, adverse effects of the thermal
mixing on aquatic life in the embayment cannot be demonstrated. See also
response to HEC-5.
RESPONSE CDC-4
The cooling pond shown in Figure 3-7 was never used for cooling the discharge
from the station. It was constructed as part of an earlier cooling system
which was subsequently abandoned.
RESPONSE CDC-5
A detailed discussion, based on all available data relating to the terres-
trial and aquatic ecology of the Apollo Beach northern embayment, is presented
in the Technical Reference Document (TRD) accompanying the Big Bend 4 DEIS.
Characterizations of the flora and fauna of the mangrove and transitional
salt prairie communities are presented in TRD Sections 2.2.4 and 5.2.4. The
areal extent of mangrove and other wetland communities within the Tampa Bay
System is delineated in Figure 2-8 and Table 2-51; Table 2-52 lists the ex-
tent of wetland losses due to development activities (as of 1972) within the
Tampa Bay System.
Comparison of the general areal extent of the mangrove community in the
embayment with that remaining in other parts of Tampa Bay is possible; how-
ever, there are no quantitative data (community composition, plant densi-
ties, associated fauna) to compare the relative quality or value of these
communities.
Section 5.3 of the TRD contains information which includes a characteriza-
tion of the embayment as to water quality (Table 5-40), benthic macrophytes
(Section 5.3.4.2), benthic invertebrates (Section 5.3.4.4), and fishes
(Section 5.3.4.5). The characterization of the fish community includes an
evaluation of the value of the embayment as a nursery area. The discussions
4-168
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cited above consider all available information on the ecology of the embay-
ment. No quantitative data exist to fully evaluate the migration of aquatic
organisms to and from the embayment or the effects of existing and future
power plant discharges on this process. However, studies conducted at the
Big Bend site have revealed the transitory nature of fish species assem-
blages in the embayment. Seasonal shifts in community structure that were
observed were related to the influx of the young of various species during
the study period. These data were collected during three unit operation
of the Big Bend Power Plant. Therefore, it is not expected that plant
discharge currents seriously affect movement of fishes in and out of the
embayment.
RESPONSE CDC-6
While the use of the area by manatees may increase with the increase in thermal
discharges, Big Bend Unit 4 is not thought to affect the overall manatee popu-
lation. The thermal discharge serves as a winter visiting site for manatees
migrating in the Tampa Bay System. Consequently, in that manatee migration
in the Apollo Beach area is anticipated to remain relatively constant, no
changes specifically attributable to Big Bend Unit 4 have been identified.
Increasing development (industrial & residential) and boating activity in
the Tampa Bay area will continue to influence the manatee population in this
area.
RESPONSE WMD-1
Comment acknowledged.
RESPONSE WMD-2
The executive summary has been rewritten to clarify this matter. See the
executive summary of this FEIS.
RESPONSE TECO-1
Comment acknowledged.
RESPONSE TECO-2
EPA was in concurrence with discontinuance of the chlorine die-away study
as indicated by TECO. The study was attempted by TECO and halted for the
reasons described. The final draft NPDES permit will contain a requirement
to conduct the study.
4-169
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RESPONSE TECO-3
EPA has included the 0.2 mg/£ TRD limit in the final draft NPDES permit.
A chlorine minimization study is under way by TECO to determine minimum
levels of chlorine necessary for biofouling control. Subsequent to com-
pletion of the study, the permit requires minimization consistent with
study results. Should conditions require further reductions in TRO discharge
subsequent to completion of the study and the die-away study (see response
to TECO 2), permit modification can be pursued at that time.
EPA notes that the Florida Governor and Cabinet have approved a variance
from the Florida water quality standards for discharges from Unit 4. EPA
concurs with the technical propriety of the variance from metal criteria.
RESPONSE TECO-4
The consent appears to be consistent with the approved State variance and the
language has been changed in the final EIS. The permit rationale will like-
wise be corrected.
RESPONSE TECO-5
Consent acknowledged.
RESPONSE TECO-6
The language has been clarified.
RE8PONSE TECO-7
Consent noted.
RESPONSE TBCO-8
The consent is correct and an appropriate correction will be made in final
draft NPDES Permit.
RESPONSE TECO-9
A groundwater monitoring program was received by EPA on July 31, 1981. EPA
has reviewed the proposed program and has requested that additional wells at
varying depths be installed to the west of the disposal areas. Additionally,
EPA has requested that TECO submit information on the construction features
of the wells. A copy of the revised monitoring plan is included in Chapter 3
of this FEIS.
4-170
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RESPONSE TECO-IO
The conment appears to be consistent with the approved State variance. The
permit rationale will be corrected.
RESPONSE TECO-11
The requested condition will be included in the final draft NPDES Permit, as
will a reopener provision relative to submission of a treatability study for
suspended metals in the slag pond effluent.
RESPONSE TECO-12
Applicable provisions will be included in the final draft permit and rationale
after action by the State of Florida and concurrence by EPA has occurred.
RESPONSE TECO-13
The reference to the flue-gas O2 or OO2 monitor was included through error.
It has been omitted in the Final Determination.
RESPONSE TECO-14
Condition 11 requires that "the applicant shall maintain records of all coal
washing and preparation activities . . ." However, in order to prevent any
misinterpretation, the reference to a minimum potential sulfur dioxide emis-
sion removal will be struck. Condition 11 will remain in the Final Determi-
nation but will be reworded for clarity and precision.
RESPONSE TECO-15
The correct number, of 15,552 tons per year, will be inserted in the Final
Determination.
RESPONSE TECO-16
Comment noted.
RESPONSE TECO-17
A copy of the current version of Chapter 17-3 is included on the following
pages.
RESPONSE HEC-1
See response to written comment SC^-7.
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s«»». n«. in
WATER QUALITY STANDARDS
CHAPTER 17-3
RULES
OF THE
DEPARTMENT OP ENVIRONMENTAL REGULATION
CHAPTER 17-3
WATER QUALITY STANDARDS
PART I Finding*, Declaration and Intent
17-3.01 Declaration tad Intent
17-3.011 Findings, Declaration and Intent
17-3.02 Minimum Conditions of AO Waters, Times
and Places
PART II Definitions
17-3.021 Definitions
PART III Water Quality Criteria
17-3.03 Water Quality Testing
17-3.031 Site Specific Alternative Criteria
17-3.04 Domestic and Industrial Waste Treatment
Requirements
17-3.041 Special Protection, Outstanding Florida
Waters
17*3.06 Thermal Surface Water Criteria
17-3.061 Minimum Criteria for All Waters at All
Times and All Places
17-3.06 Classification of Waters, Usage
17*3.061 Surface Waters: General Criteria
17-3.07 Criteria: Class 1 Waters — PubUe Water
Supply
17*3.071 Groundwaters: General Criteria
17-3.06 Criteria: Class II Waters - 8hellfiah
Propagation and Harvesting
17-3.081 Classificstion of Waters, Usage,
17-3.09 Criteria: Class III Waters — Recreation —
Propagation and Management of Flab and
Wildlife
17-3.091 Criteria: Claas I-A Waters — Potabls Water
SuppUss — Surface Waters
17-3.10 Criteria: Claaa IV Waters — Agricultural
and Industrial Water Supply
17-3.101 Criteria: Class I-B Waters — Potable and
Agricultural Water SuppUss and Storage —
Groundwaters (New)
17-3.11 Criteria: Class V Waters — Navigation,
Utility and Industrial Use
17-3.111 Criteria: Class II Waters - ShsUfish
Propagation or Harvesting — Surface
Waters
17*3.12 Definitions
17-3.121 Criteria: Class III Waters - Recreation -
Propagation and Management of Fish and
Wildlife - Surface Waters
17*3.13 Drainagt Wells, Permits
17*8.131 Criteria: Claaa IV Water — Agricultural
Water Supplies - Surface Waters
17*3.14 DrainageWeds, Applications
17-3.141 Criteria: Class V*A Waters — Navigation.
Utility, and Industrial Uss — Surface
Waters
17*3.16 Effective Date of Psnnits
17*3.161 Criteria: Class V*B - Freshwater Storage
and Utility and Industrial Uss —
Groundwaters
17*3.16 Drainage Wells, Drilling Requirements
17*3.161 Classiflsd Waters
17-3.17 Drainage WaD Permit Revocation and
Modification
17*3.18 Test Wells and Boringa
17*3.19 Abandoned WeUa
17*3.20 Pollution Surveys
17*3.21 Classified Waters
17*3.22 Application Forms
PART 1 FINDINGS, DECLARATION AND INTENT
174.01 Declaration and Intent.
Autarky *0tMl P8.
40S.031. 403.041.
403.101111. 40S.1SS. 40S.SS1 PS. Hlmury-Tmarly is-t.01, AimikM rad
RwuuibmJ m 17-MU. UTS.
17-3.011 Findings, Declaration and latent.
ID Article II, Section 7 of the Florida Constitution
requires abatement of water pollution, and conservation
and protection of Florida's natural reeourcss and scenic
bsauty.
(2) Section 403.021, Florida Statutes, declares that
the public policy of the State ia to conssrve the waters of
the State to protect, maintain, and improve the quality
thereof for public water suppHss, for the propagation of
wOdUfa, fish and other aquatic life, and for domestic,
agricultural, industrial, recreational, and other beneficial
usee. It alao prohibita the discharge of wastes into Florida
waters without treatment nscsssary to protect those
nm nf tha waters,
(3) Congress, in Section 101(a)(2) of tha Fsdsral
Water Pollution Control Act, as amsnrted, declares that
achievement by July 1, 1963, of water quality sufficient
for tha protection and propagation of fish, shellfish, and
wildlife, as weQ as for recreation in and on the water, ia an
interim goal to be aought wharsvsr attainabls. Congress
further states, ia Ssction 101(aKS), that it is the national
policy that the discharge of toxic polhitanta in toxic
amounte bo prohibited.
(41 Tha peasant and future moat benefldal uses of
sD waters of ths State have been deaignated by tha
Department by maana of the classfflrstiim system sst
forth in this Chapter pursuant to Subssction 403.061(10),
FS. Water quality standard* are eatabUshsd by the
Dspartmant to protect thess designated usss.
(6) Pollution which cauass or contributea to new
violations of water quality standards or to continuation of
siisting violations is harmful to ths waters of this State
and shall not be allowed.
(6) Tha quality of waters which exceeds the
minimum quality necessary to support the designated uae
of thoea waters shall bs protected and snhanrad.
(7) Tha quality of waters which is lowsr than that
nsesaaary to support tha designated uae of thoee waters
shall be protected and enhanced provided, however, the
Department shall not strive to abate natural conditiona.
(8) Tha higheat protection shall be afforded to
Outstanding Florida Waters.
(9) Because activitiee outeido the State somstimes
cauae pollution of Florida's watera, the Department will
4-172
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CHAPTER 17-3
WATER QUALITY STANDARDS
make every reaeonable effort to have rach pollution
¦bated.
(10) Water quality standards apply equally to and
shall be uniformly enforced in both the public and private
sector.
<11) The Department finds that excessive nutrients
(total nitrogen and total phoephorusl constitute one of the
most severe water quality problems facing the State. It
shall be the DiT.artment's policy to limit the introduction
of man-induced nutrients into waters of the State.
Particular consideration shall be given to the protection
from further nutrient enrichment of waters which are
preeently high in nutrient concentrations and sensitive to
further nutrient concentrations and sensitive to further
nutrient loadings. Also, particular conaideration shall be
given to the protection from nutrient enrichment of those
waters presently containing very low nutrient
concentrations: lees than 0.3 milligrams par liter total
nitrogen or less than 0.04 milligrams per liter total
phoephorus.
(12) Public interest shall not be construed to mean
only those activities conducted solely to provide facilities
or benefits to the general 4>ublic. Private activities
conducted for private purpoeee may also be in the public
interest.
(13) The Commission, recognising the complexity of
water quality management and the necessity to temper
regulatory actions with the technological pi ogreaa and the
social and economic well-being of people, urges, however,
that there be no compromise where pollutions! discharge*
constitute s valid hazard to human health.
(14) The Commission requests that the Secretary
seek and uae the best environmental information available
when deciaions on the effects of chronically and
acutely toxic substance* and carcinogenic, mutagenic,
and teratogenic substances. Additionally, the Secretary is
requested to seek and encourage innovative rsssarch and
developmente in waste treatment alternatives that might
better preserve environmental quality and/or at the seme
time reduce the energy and dollar coets of operation.
(16) The preeent and future most beneficial usee of
groundwaters of the State shall be protected to insure tha
availability >ni^ utility of this invaluable lesource. To
achieve such protection, the groundwaters of the State are
classified for the first time and appropriate specific water
quality criteria for thoee classes are set forth in this
Chapter.
(16) The criteria set forth in this Chapter are
minimum levels which sre neceeeary to protect the
designated usee of a water body. It is the intent of this
Commission that permit applicants should not be
penalized due to a low detection limit aaeodated with any
specific criteria.
(17) In adoption of the Outstanding Florida Waters
designated on July 13. 1978. the Commission has been
assured by the Secretary that adequate public notice has
been given that these waters were being considered for
this designation and that public comment was solicited
and considered in determining their deeignstion.
(18Ma) The revisions mads to Chapters 17-3 and
17-4 and the adoption of Chapter 17-6. Florida
Administrative Code, are designed to protect the public
health or welfare and to enhance the quality of waters of
the State. They have been established taking into
consideration the use and value of waters of the State for
public water suppliss, propagation of fish and wildlife,
recreational purposes, snd agricultural, industrial, and
other purpoeee, and also taking into conaideration their
use and value for navigation.
(b) Under the approach taken la the formulation of
the rules adopted in this proceeding;
1. Theee revisions to Chapters 17-3, 17-4 and
adoption of Chapter 17-6, F.A.C., are bassd upon the beet
scientific knowledge related to the protection of the
various designated uses of waters of the State; and
2. The mixing zone, zone of discharge, exception,
exemption, and equitable allocation provisions are
designed to provide an opportunity for the future
consideration of factors relating to localised aituationa
which could adequately be. addreeaed in thie
proceeding. Including economic aad eocial consequences,
attainability, irretrievable conditions, natural
background, and detectability.
(c) This is an even-handed and balanced approach
attainment of water quality objectives. The
Commission has q>ecifically recognised that the social,
economic and environmental coete niy, certain
special circumstances, outweigh tha social, economic and
environmental benefits if the numerical criteria are
enforced ^ statewide. It is for that reaaon that the
Commission has provided for sonee, tones of
discharge, exceptions, exemptions and other provisions in
Chapters 17-3, 17-4, and 17-6, F.A.C. Furthermore, the
continued availability of the moderating provisions ia a
vital factor providing a basis for tbs Commission's
determination that water quality standarda applicable to
water claases in the rule an attainable tailting into
consideration environmental, technological, eocial,
economic and institutional factors. The companion
provisions of Chapters 17-4 and 17-6, F.A.C., approved
simultansoualy with theee Water Quality Standarda are
incorporated herein by reference as a substantive part of
the State's comprshansive program for the control,
abatement and prevention of water pollution.
(d) Without the moderating provisions deecribed In
(b)2. above, tha Commission would not have adopted the
reviaiona deecribed in (b)l. above nor determined that
they are attainable ae generally applicable water quality
standarda.
SpadOc Authority 4010*1. 403.063. 408.0S7. 403.504. 403.704. 403.804.
403J06 F& Law laiplimwiil 403.0*1. 40t.0*l. 403.0U. 403.08*. 403.067.
403.088. 403.101, 403.141. 403.1(1. 408.181 40U0t. 403.702. 403.708.
403.*0t re Hiatary—Fonaarfcr 184.01.17-1.01. HiwitiN aad Raaambatad
S-l-7*
17-3.02 Minim am Conditions of All Waters, Times
Specific Astfearitjr 403.0*1 F8. Law '-pi-—— 401011. 403.031.403.0S1.
403.101111 TO. Hiatory- FonntrHjr 18-ft.OX, AaaM 10-1S-70. Amaadad and
HMuishaiad aa 17-3.0*1, M-79.
PART II DEFINITIONS
17-3.021 Definitions.
(1) "Acute Toxicity" shall mean the preeence of one
or more subetancee or characteristics or components of
substances in amounts which:
(a) Are greeter than one-third (1/8) of the amount
lethal to 60% of the test organisms in 96 houre (96 hr
LC50) where the 96 hr LC50 Is the loweet 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 thoee of the concentration of the
substance specified in (a) above.
(21 "Background" shall nff the condition of
waters in the absence of the activity or discharge under
consideration, based on the beet ecientific information
available to the Department.
4-173
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s—». n«. m
WATER QUALITY STANDARD8
CHAPTER 17-3
(3) "Chronic Toxicity" shell meen the pfMwci of
one or mora substances or characteristic* or componente
of substancee in amount* which:
(a) art greater than one-twentieth (1/20) of the
amount lathal to 60* of the taat organisms to M hours (96
hr LCqo) where tha 96 hr LC50 ia the lowest vahie which
ha* been determined for a epeciee significant to the
indigenous aquatic community; or
(b) may reasonably ha expected, haaad upon
evaluation by ganaratty accepted acientific method*, to
produce effect* equal to tboee of the concentration of the
nhitinffi iDieififtd in (t) ibovt«
(4) "Commission" shall mean the Environmental
Regulation Commiaaion.
(6) "Compensation Point for Pbotoeynthetic
Activity " shall mean the depth at which one percent of the
light intensity at the surface remains unabaorbed. This
depth ahall be computed aa two divided by the extinction
coefficient.
(«) 4 'Department" ahall mean the Department of
Environmental Regulation.
(7) "Designated Use" shall maan the present and
future most beneficial use of a body of water as
by the Environmental Regulation Commiaaion
by means of the classification system contained in this
Chapter.
(8) "Dominance" shall mean the prsisncs of species
or oommunitiee in greater numbers, Momasi, or anal
extent than competing spodss or communities, or a
scientifically accepted tendency of species or oommunttie*
to achieve such a status under existing or reaaonably
tatidptUd
(91 "Effluent Limitation" shall mean any
restriction eatabHohod by the Department on quentltiss,
ratee or coneentntiono of chemical, physical, biological or
other constituents which are discharged from source* into
waters of the State.
(10) "Exceptional Ecological «gmflcanoe" ahall
mean that a water body la a part of an soosystsm of
unusual value. The srosptionaf signifies nee may be in
unusual species, productivity, diversity, ecological
relationships, ambient water quality, scientific or
educational intereet, or in other aspects of the
ecoeystsm's sstting or procssses.
(11) "Exceptional Recreational Significance" shall
mean unusual vane aa a reeourco for outdoor recreation
activitiee. Outdoor recreation activitise include, but are
not limited to, fishing, booting, renneing. water skiing,
swimming, scuba diving, and nature observation. Tbe
exceptional significance may be in the intensity of pnnot
recrsational usage, an unusual quality of rscrseticnal
; a potential far umeual future
recreational uee or 1
(12) "Extinction Coefficient" shall mean: (1/D
logiotSa^D)) when D is the length of the Hght path, Sa ie
the light intensity at the eurface or the transmission value
of llgat through a distilled or deiotiiiert water sample of
thickness D. and Sq ia the light intensity at depth D or
the faranamieeion value of light through a *emple of the
water tooted of t hie knee* D. Light intenaitise or
tranemieeion vahiee shall be meaaured using a cadmium
sulfide photoreceptor or other device having a comparable
epectral response.
(13) "Groundwater" shall maan water beneath the
eurface of the ground, whether or not flowing through
known and definite channels.
(14) "Natural Background" shall mean the
condition of waters in the absence of men-induced
alterations bassd on the beet scientific informetion
available to the Deportment.
(15) "Nuisance Speciee" ahall mean species of flora
or fauna whoee preeence in sufficient number, bio mass, or
sreal extent may reaeonabiy be expected to prevent, or
unreeeonably interfere with, a designated use of those
watare.
(16) "Nuraery Area of Indigenous Aquatic Life"
shall msan any bed of the following equatic plants, either
in monoculture or mixed: Haioduia spp., Haiophila
tngtlmannii, Potamogtton spp. (pondweed), Ruppia
maritime (widgeon-gross), Sagittaria spp. (arrowhead),
Syringodlum filiform• (manatee-graei), Tkallatia
t*»tudinum (turtle graee), or VaJUtn*ria spp. (eel-greea), or
eny area uaed by the early-life etagee, larvae and post-
larves, of equatic Ufa during the period of rapid growth
and development into the juvenile states.
(17) "Pollution" shall mean the preeence in the
outdoor atmoephere or watare of the state of any
substances, contaminants, noiae, or man-made or man-
induced attention of the chemical, physical, biological or
radiological integrity of air or water in quantities or levels
which are or may be potentially harmful or injurious to
human hselth or welfare, animal or plant Ufa, or property,
including outdoor recreation.
(18) "Predominantly Freeh Waters" shall mean
thoee eurface waters in which the specific conductance of
the water at the eurface ie leee than 6,000 micromhoe per
(19) "Predominantly Marine Water*" shall mean
thoee surface waters in which the specific conductance of
the water at the surface is greater than or equal to 6,000
(20) "Propagation" shall maan reproduction
sufficient to maintain the epoefce' role In its respective
emlngical community.
(21) "Secondary and Tirtiary Canals" shall maan
any wfeoVy artificial canal or ditch which ia behind a
control structure and which la part of a water control
rystem that ie connected to the works (set forth in Section
373.086, F.3.) of a water management district created
under Section 373.069, F.S.. and that ia permitted by such
water management district pursuant to Section 373.103,
Section 973.413, or Section 873.416, FA
(22) "Secretary" shall mean the Secretary of the
Department of Environmental Regulation.
(28) "Shannon-Weaver Diversity Index" shall
mean: negative summation (from i-1 to S) of (n|/N) logx
(nj/Nl where S ie the number of speciee in s sample, N ia
the total umber of individuate in species L
(24) "Special Waters" shall mean watsr bodiee
deeignafod In eccordanes with Section 17-8.041, F.A.C.,
by the Environmental Regulation Commission for
induiion in the Special Watare Category of Outstanding
Florida Watare, ee contained in Section 17-3.041, F.A.C. A
Special Water may include ell or part of any water body.
(28) "Surface Water" meene water upon the
eurface of the earth, whether contained in bounde created
naturally or artificially or diffused. Water from natural
eprings shall be classified as surface water when it exits
from the spring onto the earths surface.
(26) "Waters"shsJl be as dsfined in Section
403.031(3), Florida Stetutee.
(27) "Zone of Diecharge" shall mean e volume
underlying or surrounding the point of discharge within
which an opportunity for the treetment, mixture or
diepereion of weetee into receiving groundweters has been
afforded.
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CHAPTER 17-3
WATER QUALITY STANDARDS
JSttJlM?
(28) "Zone ofMixing" or"MhringZone'ehalli
a vohinw of (urface watar containing the point or an* of
diecharge and within which an opportunity for the
mixture of westee with receiving surface waters has bean
afforded.
SpKiik Authority 403.0*1. 403.0(1 403.067, 403.304. 408.704, 403J04.
<03.306 PS. Law limilimintrl 403.011. 403.031. 403.0(1. 403.0M, 40*.0(6
403M7. 401.0M. 403.8M, 401 JOi P& Htohxy-PnMriy M4.ll 17-3.U.
[ J* I-79.
PART III WATER QUALITY CRITERIA
17-3.01 Watar Onality Teeting.
SpuUk AUhorfcjr 403.0(1 P& Law laphwirf 40*0»l. 403.011.40SM1.
403.101 PS. HiMOTT-PanMrly IM.03. AmbM mi tmirtini m
174.1(1. 3-1*79.
17-3.831 8iU Specific Alternative Criteria.
(1) Upon petition of an affactad parson, permit or
upon tha initiation of tha Department, appMcnnt, altar
public notice and opportunity far public bearing, and upon
affirmative demonetration that, doe to man-iadoced
cauaae which cannot be eontroOad or abated with
technology or management practicea iacfcuHng ssr©
discharge, or doe to natural catuee, certain dalfasateri
portion# of waters of the State do not meat particular
watar quality criteria contained in thie Chapter, the
Secretary may issue an order specifying an alternative
ambient watar quality criterion for each parameter and
the portion of tha waters for which such damonatration
haa been made.
(2) Tha petitioner or the Department afcaU
affirmatively demonstrate thoee critaria which the
petitioner or the Department beiievee more appropriately
apply to the waters for which the alternative criteria are
sought, based upon relevant factors which tnriwrte, but are
wnt »./> »h«l—fc—,
to which biota have "'¦f**'1 to the background, evidence
regarding ecological atraea, and edveree imparts on
adjoining waters.
(3) Tha Secretary shall specify. fay order, tha rite
specific critaria Air tha parameters which the Secretary
determinee to have bean demonatrated by the
preponderance of competent aubetantial evidence to be
more appropriate.
(4) The Department shall modify parmite of
existing eourcea affactad in a manner ennatstsnt with the
Secretary'a Order.
(3) Additional relief from critaria setobHehed by
thie Chapter may be provided through exemption
pursuant to Section 17-4.143, Florida Adminietrativ*
Code, or variancea aa provided for by Section 17-1.67,
Florida Administrative Coda.
SpmSe Authority 403.0(1. 403.0(1. 403.0(7, 401. M4. 403.704, 4MJ04,
403JOS fS. Law Vi'-tit—"f 401.011. 403.0*1. 40MST. 40MM, 4M.U1.
403.1(1. 403.101.403.(01 PS. HtoMr-Pwawfr lT-mm.AwiwW-7*.
I0-3-30.
17-3.04 Domestic end Industrial Waste'
Requirements.
Sjjafc Authority 4014*1(7) PS. Urn If !¦¦!!< 40100*. 40S4S7.
«*.*( PS. HJstary—Parmrty U444. Ammk* lfrM-70. 10-17-71.7-*-T(.
I to 17-M1. 3-1-7#.
1744M1 Special Protection, Oetstesding Florida
Water*.
(1) It shall be the Department policy to afford tha
highest protection to Outstanding Florida Waters (e
complete listing of which is provided in subsection (31)
which generally include the following aurface waters:
(a) watere in National Parka, Wildlife Refiigas and
Wilderness Areaa; *"^
lb) watera in the State Park System end Wilderaeee
Anas; and
to) waters in Environmentally Endangered Land*
which have bean acquired under Chapter 269, Florida
Statutea; and
(d) rivers deeignetad under the Florida Scenic and
Wild Rivers Program or the National Wild and Scenic
Khan Acts
(a) waters within National Saaahoraa, National
Marine 8anctuariae, National Eetuarine Sanctuaries and
certain National Monuments; and
(0 watere in Aquatic Preeervee created under the
provieiooe of Chapter 268. Florida Statu tea; end
(g) watera within the Big Cypreea National
Freshwater preearve; and
(h) Special waters as listed in 17-3.Ml(4Mg>-
(2) Each watar body demonstrated to be of
exceptional recreational or ecological significance may be
dtsjgwtf^ as a Special Watar. The following procedure
shall bo uasd in designating a Special Watar aftar the
adoption of thie rale:
(a) Rulemaking procedure* pursuant to Chapter
120, FA. and Chapter 17-1 F.A.C., shall be followed;
(b) At leaet ooe fect-flnding workshop shall be held
in the afleeted area:
Id AO local county or municipal governments and
state legislators whoss districts or jurisdictions include all
or part of a Special Water shall bo notified at least 60 days '
prior to the workshop in writing by the Secretary:
Id) A prominent public nodes shall be placad in a
newspaper of general circulation in the area of the
propoaad Spedal Watar at leaet 60 days prior to tha
Is) An scooomic impact analysis, consistent with
Chapter ISO, shall bs prepared which provides a general
analysis of the impact on growth and development
iackiding such factors as impacts on planned or potential
industrial, ^agricultural, or other development or
Commission may designate a water of the
ss a Special Water aftar making a finding that the
watera are of exceptional recreational or ecological
and a finding that tha environmental, social,
and f*"*1 benefits of the action outweigh the
environmental, eocial. and economic coeta.
(3) The policy of thie eection shall be implemented
through the permitting procees pursuant to Section
17-4.242, FA.C.
(4) Outstanding Florida Waters:
(a) Waters within National Parks
4-175
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WATER QUALITY STANDARDS
CHAPTER 17-3
National Park
Evargiadas
(b) Waters within Wildlife Raf«t«s
WOdHfa Rafaga
Loxahatcha*
Pig Island
St. Vincent
ChMaahowiUlu
Andota
Pinellas
Okaafanokaa (Florida Portion)
Andota Island
Pelican I aland
Hob* Sound
Passage Kay
Caloosahatchee
Commtj
Monroe/Dada/Collier
Ceutjr
Palm Bench
Oull
Franklin
Citrus/Hernando
Pasco
Pinellas
Baksr
Indian River
Indian Rivar
Martin
Msnstee
La*
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Supp. No-121
WATCH QUALITY STAVDABna
CHAPTER 17-3
Lake Woodruff
St. Mark's
National Kay Deer
Great White Heron
Kay West
Pint Island
Matlacha Paaa
J. N. "Ding" Darling
Island Bay
Cedar Keys
Chineegut
Merritt Island
Egmont Key
St. Johns
(c> Waters within State Parka or Recreation Areas
State Park or Recreation Area
Alfred B. Maclay State Ornamental Garden
Anaatasia State Recreation Area
Bahia Honda State Recreation Area
Basin Bayou State Recreation Area
Bill Bagga Cap* Florida State Recreation Ana
Blackwater River State Park
Blue Springs State Recreation Area
Caladeai Island State Park
Cheloka State Recreation Area
Collier—Seminole State Park
Dead Lakes State Recreation Area
Eden State Ornamental Garden
Falling Waters State Recreation Area
Faver—Dykes State Park
Flagler Beach State Recreation Area
Florida Caverna State Park
Fort Clinch State Park
Fort Pickens State Park
Fred Gannon Rocky Bayou State Recreation Area
Grayton Beach State Recreation Area
Highlands Hammock State Park
Hillsborough River State Park
Hontoon Island State Park
Hugh Taylor Birch State Recreation Area
Ichetucknee Springs State Park
John Pennekamp Coral Reef State Park
John U. Lloyd Beach State Recreation Area
Jonathan Dickinson State Park
Lake Griffin State Recreation Area
Lake Kissimmee
Little Talbot Island State Park
Long Key State Recreation Area
Manatee Springs State Park
Mike Roess Gold Head Branch State Park
Myakka River State Park
Ochlockonee River State Park
O'Leno State Park
Oscar Scherer Recreation Area
Pahokee State Recreation Area
Pepper Park State Recreation Area
Ponce de Leon Springs State Recreation Area
Ravine State Ornamental Garden
St. Andrews State Recreation Area
Sebastian Inlet State Recreation Area
Suwannee River State Park
Three Rivers State Recreation Area
T. H. Stone Memorial St. Joseph Peninsula State Park
Tomoka State Park
Torreya State Park
Washington Oaks State Ornamental Garden
Wekive Springs Stete Park
Voiuaia
Jeffereon/Wakulla
Monroe
Monroe
Monroe
Lee
Lee
Lee
Charlotte
Levy
Hernando
Volusia/Brevard
Pinellas
Brevard
Cooaty
Leon
St. John*
Monroe
Walton
Dade
Santa Roea
Voiuaia
Pinellas
Dede
Collier
Gulf
Walton
Washington
St. Johaa
Flagler
Jackson
Nassau
Escambia
Okaloosa
Walton
Highlands/Hardee
Hillsborough
Volusia/Lake
Broward
Columbia
Monroe
Broward
Martin
Lake
Polk
Duval
Monroe
Levy
Clay
Manatee/Sarasota
Wakulla
Alachua/Columbia
Sarasota
Palm Beach
St. Lucie
Holmes/Walton
Putnam
Bay
Indian River
Hemflton/Madison/Suwannse
Jackson
Gulf
Voiuaia
Liberty
Flagler
Orange/Seminole
4-177
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CHAPTER 17-3
WATER QUALITY STANDARDS
p. No. m
(d) Water* Within Environmentally
Lands Which Have Bin Parchsssd by the State.
Environmentally FailaagsrsH Lands
Weedon Island
Fakahatchee Strand/Big Cypress Bend
Volusia Recharge Area
River Rise (McLeod Ranch)
San Pels sco Hammock
Three Lakes Ranch
Lower Apalaohieola River Tracts
Palm Beach C' junty Everglades Tract
Paynes Prairie Stats Preserve Addition
Lower Weldva River Corridor
Cayo Costa North Captivs Islands
Charlotte Harbor
Big Cypress National Preserve
Toeahatchee State Preserve
(el Waists within National I
NatioaaJ
Gulf Islands
Canavsral
tf) Watsrs within State Aqnatk ]
Aquatic Prsssrvss
Cape Romano—Tan Thousand Islands
Nassau Rivsr—St. Johns River Marahsa
St. Joseph Bay
Apalachicola Bay
North Fork, St. Lucie
Intracoastal Watsrs—Jensen Beach to Jupiter Inlet
Loxahatcbee Rivsr—Laks Worth Cresk
Fort Clinch Stats Park
Cockroach Bay
Boca Ciega Bay
Caladesi Island
St. Martin's Marsh
Alligator Harbor
Biscayns Bay
Estero Bay
Pellicer Creek
Tomoka Marsh
Coupon Bight
Lignum vitae Kay
Cape Haaa—GupariDa Sound
Pine Island Sound
Matlacha Paaa
Yellow Rivsr Marsh
Fort Pickens State Park
IjIm Jackson
St. Andrews State Park
Rocky Bayou State Park
Mosquito Lagoon
Banana Rivsr
Indian Rivsr Malabar to Sebastian
Indian Rivsr Vsro Beach to Ft. Pisna
Pinellas County
Canty
Pinellas
Collier
Volusia
Osceola
Alachua
Osceola
Franklin/Gulf
Palm Beach
Alachua
Lake/Seminole
Lee
Charlotte
Coffiw/Dada/Moaroe
Orange
Caanty
Escambia/Santa Roaa
Brsvsrd/Votusia
Coaaty
ColUsr
Nassau/Duval
Gulf
Franklin
St. Lucia/Martin
Martin/Palm Beach
Martin/Palm Beach
Nassau
Hillsborough
Pinellas
Pinellas
Citrus
Franklin
Dade/Monroe
Lee
St. Johns/Flagisr
Volusia/Flaglsr
Monroe
Monroe
Chariot ta/Lee
Lsa
Lea
Santa Roaa
Escambia
Bay
Okaloosa
Volusia/Brevard
Brevard
Bmvard/lndian Rivsr
Indian fUverfSt. Luds
Ptnsllss
(g) Special Watsrs
Ochloekonsa River
Wakulla Rivsr
St. Marks River—except that part bstween Rattlsaaaks
Branch and the confluence of the St. Marks and
Wakulla Rivers.
Wsrisss Rivsr
AodOa Rivsr
Apalachicola River south of northsrn Golf County Lins
Chipola River
Shoal River
Choctawhatchae Rivsr
Blackwstsr Rivsr
Psrdido Rivsr
Suwannee Rivsr
4-178
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Supp. No. 191
WATER QUALITY STANDARDS
CHAPTER 17-3
-------
CHAPTER 17-3
WATER QUALITY STANTtAttng
3«w- wo. m
with a temperature at the POD mora than 3*F higher than
the ambiant (natural) temperature of eny lake or roesrvoir
ahall not bo discharged into auch laka or nawvolr.
Further, no heated water with a temperature above 90'F
shall be discharged into any (rash watari is Northern
Florida regardloee of the ambiant temperature of the
RBW. In Fenmeular Florida, heated waters above M'F
shall not be diacherged into fraah waters.
(il) Coastal Watera - Heated water with a
temperature at the POD mora than 2*F higher thin the
ambient (natural temperature of the RBW shall not be
discharged into roaetal waters in any zona daring the
montha of June, July, Auguet. and September. Daring the
remainder of the year, heated water with a temperature at
the POD mora than 4'F higher than the ambient (natural)
temperature of the RBW ahall not be diaehargad into
coastal watera to aay tone. In addition, during June, July,
Auguat, ead September, no heated water with a
temperature above tt'F ahall be diacharged into
waters. Further, no heated water with a temperature
above 90*F ahall be discharged into coastal waters during
the period October thru May.
(iii) Open Watera —Heated water with a
temperature at the POD up to 17*F above ambiant
(natural) temperature of the RBW may be diecharged
from an open or cloeed conduit into open waters under the
following reetraints: The surface temperature of the RBW
shall not be raised to mora than 97*F and the POD muet
be sufflcisnt distance offshore to ensure that the adjacent
coastal waters are not bee ted beyond the temperaturee
permitted in such watera.
(iv) Cooling Ponds — The temperature for heated
watar diacharged from a cooling pond shall be meeeured
at the POD fron the pood, and the temperature limitation
shad be that specified tor the RBW.
-------
»w N». IM
WATER QUALITY STANDARDS
CHAPTER 17-3
f any of the following su
quality criteria constitute* pollution. Additional more
stringent or alternative criteria than indicated in this
paragraph may, however, be specified for individual
daaaaa of water under Sections 17-3.091, 17-3.111,
17-3.121, 17-3.131, and 17-3.141 of this Chapter.
(a) Arsenic — shall not exceed 0.06 milligrams per
liter.
(b) BOD — shall not be increased to exceed values
which would cause diaeotved oxygen to be depressed
below the limit eetablished for each class and. in no caee
shall it be great enough to produce nuisance conditions.
(c) Chloridee — in predominantly marine wstsrs,
the chloride content shall not be increased mors Chan ten
percent (10%) above normal background chloride content.
Normal daily and seasons! fluctuations in chloride levels
shall be maintained.
(d) Chromium — shall not exceed 0.60 milligrams
per liter hexavalent or 1.0 milligrams per liter total
chromium in effluent discharge and shall not exceed 0.06
milligrama par liter total chromium after reasonable
mixing in the receiving water.
(el Copper — shall not exceed 0.6 milligrams par
liter. -
-------
CHAPTER 17-9
WATER QUALITY 8TANDARP8
J*S£N*Ut4
theee groundwater quality standards and associated rata
provisions. Said Taw Force shall ba rampossd of sixteen
par son a. with om representative from aach of tba five
watar management diatricta; five rspceaantativao from
affected industry, five fron environmental grows or
other group* tha Chairman of tha CoounMon shall elact
to in vita to participate; and om nymalithn from tba
Department who ahall act as Chairman of that Taak
Fores. la developing tha propoaad rsviaiona, tha Taak
Forca shall considsr tha variona geologic aad hydrolojic
provinces of tha State; tha moat beaefidal usss of tha
groundwaters of tha Stata; critaria nacaaaary to pro tact
thoaa oaaa; aad tha integration of groundwater quality
aad quantity maaagameat. Said Taak Fane ihd provida
writtaa atatua raporta to tha Cuuimiseion No later than
January 31, IMS, tha Commission ahall condder at a
public Hearing any propoaad revisions.
Ml Tha Department most attempt to protect tha
aoat beneficial oaaa of tha groundwater* of tha 8tata to
aaaura continued availability of thia iavaluabla resource.
To aehiava tha aocoesary protection, yortfic standards
reflecting thaaa beneficial uaaa ara aat forth la thaaa
Chaptar*. However, recognising tha complaxitiaa aad
concarns of impUmaatiog ground watar ataadarda, tha
CoauBiaakia ahall review tha groundwater ataadarda
eoataiaad herein, togathar with tba raport of tha Taak
Forea aatabUahad pursuant to (5) abova at a public hearing
no la tar than January 31. 1962. Unlaaa tha Commission
affirmatively datarminaa that tha groundwatar ataadarda
remain appropriate, or amends than aa it da una
aacaaiary, all aueh groundwatar ataadarda ahall ba
repealed effective January SI. 1962. In the event of repeal
of groundwatar ataadarda pursuant to thia Suboection,
any ragulstious spplkabla to grouadwatara at tha data of
tha adoption of this aactioo shall apply. Psrmite iasuad
prior to January SI, IMS in armrriance with aueh
pwmdwatar ataadarda ahall remain in tall forca and
enact until aueh panaita expire, ai
in aaeordanea with annlieahia nilaa i
andasAaHiw*) m>ai. aauat. mm. mMt. rn.it. mum ni
u« WMriatML 4MMI. man. mtm. m.uu miai.
miat, mJM, *m.m. «n.rea re. mp w.. n-n —- i '
MM.
174M Critaria: Oaaa II Waters — ShsUileh
ar-*k AiKtwk) «oaaat ra. u* iMiwm man. Tha propoeed reclassification will establish ths
present and future moat beneficial uaa of the watara; aad
(hi Such a recta aaiflcatloa is ciaariy in the public
internet.
W Reclassification of watara of the Stata which
estabUehee more stringsnt criteria than praeently
oofehHshad by this Chaptakshall be adopted, only upon
additional affirmative finding by tha Environmental
Regulation ^iut the propoeed daaignatad uaa
ia attains his, upon considsration of environmental,
technological, sodal, economic, and institutional factors.
%muic ah—si 4oa.ni, moai. toaasr, wioea, 40j.ni, 4otiai.
mist. MUM. 401104. 40».70t. 401.TM n Hkwnr-rwwwty ta«.oa.
17-101, AmbM ad H—bwiS t-lT*.
I74M Criteria: Claee 111 Watere - Recreation
id Menagament of Pieh and Wildlife.
s*MUe «aaaai rs. 40ieii. 40>.mi. «aaaai. 4oa.ioi n.
Hutorr-Hmmt» MM. AmaM frl»Tt MS-f fcT*U AawW mi
m 17-a.iai. »-i-7e
174,091 Criteria: Claaa I-A Watara — Potabla
Wetar Seppin — Surface Waters. Ths criteria listed
below are lor surface watara designated for use aa a
potable euppty. The standards contained in Sections
17-S.061 aad 17-S.M1, F.A.C., shall apply to all watara of
this class, unlssa mora stringent levels ara specified below.
Tba following critaria are to be applied except within
sones of mixing:
(1) Alkalinity — shall not be deproeaad below 20
BiOigrama par liter as CaCOj.
(2) Ammonia (un-kmisad) — shall not exceed 0.02
aillifnmt p$t
ffl Bacteriological Quality — Coliform group shall
notexceed 1.000 par 100 milliliters ss s monthly average,
4-182
-------
•ggJfeJM,
WATCH QUALITY STANDARDS
CHAPTER 17-8
using eithar moat probable numbar (MPN) or mambrana ISO (in milligrama par liter of CaCOs), and ahall not axcaad
filter (MP) counta; nor axcaad 1.000 par 100 ariMitara in i.io milligrama par Utar in haniar watera.
mora than 20% of U>a aampkaa aiaminad during aay (61 Biologieal Integrity — tha Shanaon-Waavar
month; nor axcaad 3.400 par 100 milliliters (MPN or MP divaratty indax of banthic macroinvartebratea ahall not ba
count) at any tima. Based on a minimum of fiva samples reduced to laaa than 78% of background lavala aa
taken ovar a 30-day period, tha facal cotiform bacterial maaaurad uaing organiama rateinad by a U.S. Standard
leval ahall not axcaad 200 par 100 milliliters aa computed No. 90 aiava and collactad and compoaited from a
by tha log moan, nor shall mora than 10% of tha total minimum of thraa Hester-Dandy typa artificial aubatrata
i
par Utar in watera with a hardasaa aqvil to or laaa than CaCOg) aqnl to or laaa than 160, and ahall not axcaad 1.2
micrograms por liter in hardar watera.
4-183
-------
N«. HI
WATER QUALITY STANDARDS
CHAPTER 17-3
micrograms per liter in harder watera.
(8) Chlorides — shall not exceed two hundred fifty
(250} milligrams per liter.
(9) Chlorine (total residual! — shall not exceed 0.01
milligram* per liter.
(10) Copper — shall not exceed 30 micrograms par
liter.
(11) Cyanide — shall not exceed 5.0 micrograms per
liUr.
(12) Dissolved Oases — shall not exceed 110% of
the saturation value for gasee at the existing atmospheric
¦wH hydrostatic nroesuro.
(13) Dissolved Oxygen — shall not bo leas than 6
milligrams par liter. Normal daily and seasonal
fluctuations above this level shall bo maintained.
(14) Dissolved Solids — not to exceed five hundred
(600) milligrams per liter as a monthly average or exceed
one t (1,000) milligrams par liter at any time.
(15) Fluorides — shall not exceed 1.6 milligrams per
liter.
(16) Iron — ehall not exceed 0.3 milligrams per liter.
(17) Lead — shall not excsed .03 milligrams per
liter.
(18) Mercury— shall not exceed 0.2 micrograms per
liter.
(19) Nickel — shall not exceed 0.1 milligrams per
liter.
(20) Nitrate — shall not exceed 10 milligrams per
liter as N or that concentration determined in (21) below.
(21) Nutrients — In no case shall nutrient
concsntrations of s body of water be altered so as to cause
in natural populations of aquatic flora or
(26) Selenium — shall not exceed 0.01 milligrams
per liter:
(26) Silver — shall not exceed 0.07 micrograms per
liter.
(27) Transparency — the depth of the compensation
point for photosynthetic activity shall not be reduced by
more than 10% as compared to the natural background
value:
(28) Zinc — shall not exceed 0.03 milligrams per
Uter.
(22) Peatlctdee and Hsrbicidee:
(a) Aldrin plus Dieidrin — shall not exceed 0.003
micrograms par liter.
(b) CMotdane — shall not bxceed 0.01 micrograms
per liter.
tc) 2-4-D — shall not exceed 100 micrograms per
liter.
(d) 2,4,6-TP — shall not exceed 10 micrograms par
liter.
(a) DDT — shall not exceed 0.001 micrograms per
Uter.
(f) Demeton — shall not exceed 0.1 micrograms per
Uter.
(g) Endoaulfan — shall not exceed 0.003
micrograms per Uter.
(h) Endrin — ehall not sxceed 0.004 micrograms per
Uter.
(il Outhion — shall not exceed 0.01 micrograms per
liter.
(j) Heptachlor — shall not exceed 0.001 micrograms
per Uter.
(k) — shall not exceed 0.01 micrograms per
liter.
0) Malathion — ehall not exceed 0.1 micrograms per
liter.
(m) Methoxychlor — shall not exceed 0.03
p|f yter.
(n) Mirex — shall not exceed 0.001 micrograms per
liter.
(o) Parathion — shaU not exceed 0.04 micrograms
per Uter.
(p) Toxaphene — shall not exceed 0.006 micrograms
per liter.
(23) Phthalate Eaters - shall not exceed 3.0
micrograms par liter.
(24) Polychlorinated Biphenyla — shall not sxceed
0.001 micrograms per litsr.
! Antkeritjr 403.0S1. 403.081. 401.017. 401.804. 403704. 403804 PS.
Law lBjlMHUii 401411. 40S.SS1. 403,081. 403.08*. 401.141. 401.181.
403.183, 40SJO1 403.701. 401.708 PS. Htol«r-POTmriy 28-4.07. 11-3.07.
I 7-3-73. AmM md immmimtd 3-17-8.
17-3.10 Criteria: Class IV Wetere — Agricultural
end ladaetrial Water Sapply.
Spadflc Awhority 401.081 PS. Law lT»[ilim ill I 403.031.403.031,401.081.
401.101 PS. HMonr—Potaarly JS-8.10. />,¦»¦ llld 8-10-71. 8-30-7L Amidid
I a* 17-3.131. J-l-71.
17-3.101 Criteria: Claee I-B Watere — Potable and
Agrleultaral Water Sappliee and Storage —
Groandwatere. As stated in Section 17-3.161, F.A.C. all
ground watere with total dissolved solids levels of less
than 10,000 milligrams per' er are classified aa Class I-B.
The criteria contained in Section 17*3.071, F.A.C., apply
to all watera in this classification unlsss more stringent
levels are specified * low. The criteria contained in
Section 17-3.061(1), F.a.C., and the following criteria are
to be applied except within tonee of discharge:
(1) Areenic — ehall not exceed 0.06 milligrams per
Uter.
(2) Barium - shall not excsed 1.0 milligrams per
(8) imt ¦vwaerf 0.01 mflllerems per
tttMT.
(4) Chromium — shall not exceed 0.06 milligrams
par liter.
IS) Endrin - shall not sxceed 0.2 microgram! par
litre.
(6) Fluorides - shall not sxceed 1.5 milligrams par
Uter —L— background information bdicatae prior
of higher levels than 1.6 milligrams per Uter, in
which case thoaa higher levels are not to be exceeded.
17) Lindane - shall apt sxceed 0.004 milUgrams par
liter.
(8) Lead — shall not exceed 0.06 milligrams per
Klkflf*
(9) Mercury - shall not exceed 0.002 milligram* per
liter.
(10) Methoxychlor - shaU not exceed 0.1
per liter.
(11) Nitrate - shall not exceed 10.0 milligrams per
Uter as N.
(12) Radioactivs Subetancee:
(a) radium 226 and 228 — shall not
exceed five pfcocuriae par liter.
(b) Gross alpha particle activity including radium
226, but excluding radon and uranium — shall not exceed
fifteen uitonirtee per liter.
(13) Islenlum — shall not sxceed 0.01 milligrame
per liter.
(14) SOver - shall not exceed 0.06 milUgrams per
Uter.
(16) Subetances shall not be present in
concentrations which injure, are chronically toxic to. or
produce significant adverse physiological or behevioral
reeponeee in humans, animals, or plants.
(16) 2. 4-D - shall not sxceed 0.1 milligrams per
liter.
(17) 2, 4, 6-TP — shstt not exceed 0.01 milligrams
par Uter.
4-184
-------
CHAPTER 174 WATER OU
(18) Toxaphene — shall not ucaad 0.006 nflttgruu
per liter.
SpedJIc Authority 4030*1. 403 0*3. 401.0*7. 401.104. 403.704, 401 MM n.
Law lapkmwMd 401.011. 401.0*1. 403.0*1. 40S.0M. 401141. 4011*1.
401.1(1. 401101.401.70S. 40170* FS. Hiaury-Naw H-Tt.
174.11 Criteria: Claae V Watere - Navigation,
Utility, aad laduatrial Uh.
SpadAe Aatkaritr 4010*1 FS. Lw till 401011.4010*1. 403JJS1.
401.101 ra. HiMr~TMrir im.ii, mt amm k
17-1.141. S-l-Tt.
174.111 Criteria: Oaae II Watare - Shellfish
Propagatfw or Horveetfcg — Surface Wat**. The
criteria Hated below art for surface watara riassiflsd at
Claaa II. Ilia standards contained in Section 174.081 and
174.061, F.A.C., alio ahall apply to all waters of this claaa,
ualaoa additional or more atringent levels an apaciftad
balow. Th. following criteria ara to ba appHed except
within aooaa of mixing:
(1) Aluminum —shall not oxessd 1.6 milligrams psr
litar.
(2) Antimony — (hall not »«c**d 0.2 inBHgraiin per
litar.
(31 Bacteriological Quality — the miri oohfonn
MPN (fcioet Probable Number) of water ahaii ot aieeed
sovsnty (70) per hundred (100) miBiHtsrs. am. not more
than tan percent (10%) of the aamplse shall exr da MPN
of two hundred and thirty (260) per one ha dred (100)
millflitera. The fecal cottform bacterial law. shall not
exceed a tnedien value of 14 MPN per 100 mi .fHtara with
not more than ten percent (10%) of the aampk «"g
43 WPN per 100 miMiUra.
(4) Biological Integrity — the Shann a-Weaver
diveraity index of benthic macroinvertebratee a
-------
!¦>>. H*. Ill
.VATEH QUALITY 8TANDARD8
CHAPTER 17-3
(3) Ammonia lun-ionixed) — shall not exceed 0.02
milligrams par liter in predominantly freeh water*.
14) Antimony — shall not exceed 0.2 milligram* par
Uter in predominantly marina watara.
(5) Bacteriological Quality — fecal cottlorm bacteria
ahaB not exceed a monthly average of >00 par 100 ml of
aample, nor exceed 400 par 100 ml of aampla in 10 parent
of the samples, nor azcaad 800 par 100 ml on any ana day,
nor exceed a total cotifonn becteria count of 1,000 par 100
ml aa a monthly avaraga. nor exceed 1.000 par 100 ml in
mora than 90 psreent of the aamplaa examined during any
month, nor exceed 2.400 par 100 ml at any time. Monthly
avaragaa ahafl ba aspaaaaed aa geometric maina baaad on
a mhlmttiB of 10 aamplaa tahan ovar a 30 day pariod.
Either MPN or MF counts may ba HtWaad
(61 Baryltiuin — in predominantly freeh watara shall
not aseaad 0.011 miUgrama par tttar in watara with a
hardnees equal to or laaa than 180 (to mflMgrame par Utar
of CaCOg) and ahall not exceed 1.10 mOUgrania par litar in
hardar watara.
(7) Biological Integrity - tha 8haamon-Waavar
divaraity index of baothic macrotnvertabntao ahall not ba
reduced to laea than 76 parcent of oatabliahed background
Imh aa maaeured using organiama retained by a U.S.
Standard No. 30 aiava and. in predominantly fraah waters,
collected and compoaited from a minimum of three
Heetar-Dendy type artificial substrate aaanplara of 0.10 to
0.16 m2 ana each, incubated lor a period of four wseka;
fan predominantly marina watara, noBacted and
a of thraa natural sohatrate
a. taken with Fonar type samplers with i
>of 228<
m Bromine
0.1 mUHgrssM par tttar in
watara, and hromatea shaB not
100 mfflgraow par Utar In predominantly marina
W
liter in predominantly marine waters; shal not exceed 0.8
micrograms par litar in predominantly fraah watars in
water with a hardneee tin milligrams per Utar of CaCOg) of
laaa than ISO. and shall not exceed 1.2 micrograms par
Utar in hardar watara.
<10) Chlorine (total reoktnsl) — shaB not sxesed 0.01
milUgrama par Utar.
(Ill Copper — ahall not aseaad .016 mBHcnuaa par
Utar in predominantly marine watara; ahaB not exceed .OS
milligrams par Ular In predominantly fraah waters.
<121 Cyanide — ahall not exceed 6.0 micrograms par
Utar.
(IS) Dieeotvad Oaaaa - shaB not aseaad 110% of
the saturation value for gaaaa at the existing atmospheric
and hydroetatlc praaeuraa.
(14) Dissolved Oxygen — in predominantly fraah
watara. tha coaaaotrathwi ahaB not ba laaa than 6
In ineiliimlnanllr marina watara, the
Utar in a 24-boor pariod and shall never ba lsaa than 4
milligrams par utar. Normal dally and seasonal
OnetuatioM above theee levela ahaB ba aaaintained in both
predominantly freeh watara and predominantly marina
watara.
(16) Finoridee-shall not exceed 6.0 milligrains per
Utar in predominantly marina watara.
(ie> Iron - shaU not exceed 1.0 milligrams per liter
in predominantly fraah watara; 0.S milligrams per litar in
marina watara.
(17) Land - shall not exceed .08 milligrams per liter
in predominantly freeh waters.
(18) Mercury — shall notaxcoed 0.1 micrograme per
liter in predominantly marine watars; shall not exceed 0.2
micrograms par liter in predominantly freeh watara.
(19) Ntekal — shall not axeaad 0.1 milligrams per
Uter.
(SO) Nutriente — In no caee shall nutrient
concentrations of a body of water be altered so aa to cauae
an imbalance in natural populations of aquatic flora or
(311 Foeticides and Her bidden
(a) Aldrin plus Dieldrin — shall not exceed 0.003
per Uter.
Ik) Chlordaae — shaB not exceed 0.01 micrograme
Utar in predominantly fraah watara and ahall not
0.004 micrograms par Utar in predominantly
watara.
le) DDT — shall not aseaad 0.001 micrograms par
(d) Dr oeton - shaU not exceed 0.1 microgram* par
Utar.
Utar.
(•) Endosulfan — shall not exceed 0.008
par Utar in predominantly fraah waters and
ahaB not exceed 0.001 micrograms per Utar in
predominantly marine watara.
if) Bndrin — ahaB not exceed 0.004 micrograms par
Utar.
If) Guthioo — ahaB not exceed 0.01 micrograms per
tttar.
(h) Keptacblor — shall not exceed 0.001
akrofnuna par Utar.
0) TJrdano — ahaB not axcaad 0.01 micrograms per
Btar In predominantly freeh waters and shall not exceed
0.004 aakrograma par Utar In predominantly marina
0) Malathion — ahaB not eseeed 0.1 micrograme
par Btar.
(k) MVthoxyehlor — ahall not exceed 0.08
v Utar.
0) Mi* ix — ahaB not axeaad 0.001 micrograme par
(m) Parathion — ahaB not exceed 0.04 micrograms
par Utar.
(n) Toxaphaae — shall not exceed 0.006 micrograms
par Utar.
(22) pH — pH of receiving watara shall not be
ceueed to vary more than one (1.0) unit above or below
normal pH of predominantly freeh watara aa defined in
Section 17-3.021, F-A.C., and eoeatal watara aa defined in
Section 17-3.060XC), F.A.C.; and not mora than two
tenths (0.2) units above or below normal pH of open
watara aa defined in 8ection 17-3.06
-------
chapters
WATM QUALITY STAND All n«
i Awhtrftv 4NMI, 401001 401007. 40*194. 400.104. 401004 n
I* «MM. 4oa.oii, 4«.orf, 40mm, <01.141. «m.i«i.
4011*1 403.Ml 401.701, 401.70* PS. >UMry-r«nMrty 1*4.11, 171.11,
* 1
(29) Zinc — ahall not exceed .03 mflhgrama par ttt«r
in predominantly freah watere.
¦¦mite AatlMrttjr 400.001. «tMM 400.087. MMi 401.704. «MM H
Uw !f"ir-ltl< 400.011. 401.0(1. 401.0(7, 401001 40S.I4I. 4M.MI.
401191. 4O»*01, 40I.T0t> 401700 PS. NlMvr-rwwriy JM*. IT-MS,
i Mo-n MO-rt. 1-t-n, amM mi i-i-to.
17-8J8 Draiaag* WeBe,
Specific AMhoriijr 401091 PS. Law
401.1M PS. muBiy-PofWly M4.U.
403.011. 401011.401001.
n-rt.
17-3.131 CHtarist CUm IV Watara - Agrientaml
Sappllee Swfaee Watara. The critatia Hstsd below an for
eurface watara da ad Sad aa Claaa IV. Tha otaadarda
eotebhaheri in Sectiona 17-3,061 and 17-MI1, F.A.C- also
apply to all watara of thia diiaWtatl«i, unleeo add It tonal
or more etringant critaria ara apadfiad below. Tha
foBowiag criteria ara to ba applied eicopt within aoaeo of
(1) Alkalinity — ahall not aicaad WO aiiMigraaia par
litar aa CaCOg.
(S) Beryllium — ahall not exceed 0.1 aiMgrama par
litar la Watara with a hardaaas la miBigrama par hter of
CaCf^ of laaa thaa 860 aad aha! not larcaad 0.5
par Utar ia harder watara.
(3) Bona — ahall aot aicaad 0.76 aUinaa par
''»er.
(4) Color, odor, aad taata producing aubataaoaa aad
other dalatarioua aubataaoaa, including other chondral
oompouDda, attributable to domeetic waataa, iaduatrial
waataa, aad othar waataa — ooly soch amouata aa wffl aot
render tha watara unauitabla for agricultural irrigation,
Uveetock watering, iaduatrial fooling, iaduatrial prooaaa
watar aupply purpoaaa or fiah aurvhraL
(5) Cyanide — ahall aot aicaad 6.0 micrograma par
litar.
(6) Diaaohrad Oiygaa — ahall aot average laaa thaa
4.0 milligram* par litar ia a 24-hour period aad ahall never
hm 1ms 3.0 ittflliffifly sir Hfctf.
(7) Iron — ahaO aot aicaad 1.0 milllgraas par litar.
(() Mareury — ahafl aot exceed 0.1 i
Utar.
(9) Niekal — ahall aot ixoaad 0.1
Utar.
(10) pH — aot mora thaa oaa (1.0) nait from tha
aormal or not laaa thaa aix <6.01 aor graatar thaa oight aad
ooa-balf (8.61.
flnirlllr Aethority 401.0(1. 401001 40UST. «aJH 4017SI. 40M04 Pa.
Uw ImpteoMOUd 4010*1. 401.0(1, 4010(7, 40MM. 408.141. 481.1*1.
401.iat. 4oa.mi. 4oi.Tot. 401100 ps. in*«f f—rtr to4.io. i7-iio.
1(-10-71 M0-71 AmM «a( (¦liwlwirt H-Tt.
17-3.14 Praiaaga Walla,
aoteMc Authority 4010(1 PS. Uw Iq
40J.1U PS. HiMMy-PtMtjr 104.14.
401011.400.0(1.401.101.
n-is.
17-3.141 Criteria: Claaa V-A Watara - Navigatioa,
Utility and Indnetrial Uee-Snrfaoe Waters. The critaria
lis tad below are for aurfaca watara claaaffled as Claaa V-A.
Tha atandarda contained ia Soctiono 17-8.061 aad
17-3.061. F.A.C.. alao apply to all watara of thia
claaaification, ualaaa additional, alternative or mora
stringent critaria ara apadfiad balow. The following
critaria ara to ba applied aieapt within aoaae of mixing:
(1) Cyaaida — ahall aot aicaad 6.0 mferograma par
liter.
(2) Diaaolvad Oiygaa - ahall aot be laaa than 2-0
m|mp.«« par liter.
(31 Mercury- ahall not eiceed 0.2 micrograma par
Utar.
(4) Odor producing eubatancea — ooly ia auch
amouata aa will not uareaeoaably interfere with the uee of
the water for the deaigaated purpoee of thia claaaificatioa.
(6) pH — not lower than 6.0 aor greater thaa 9.6
eicapt certain awamp watara which may be aa low aa 4.6.
17-3.16 Bffaetive Date of Peraita.
AMhdiljr 401001 PS. law laipliaiam 401011, 401001,401.1M
** lumtr-hmmir iM.ii, iu^mM a-i-Tt.
17-3.161 Critaria: Claaa V-B Watare - Freehwater
Storage aad Utility aad ladaatrlal Supply —
(hoaadwateao. Aa atated ia Section 17-3.161, Florida
Adariaietrative Code, all grouadwatara with total
diaeoived aohda equal to or graatar thaa 10,000 mflHgrama
par Utar ara daeaiaedaa Claaa V-B. Eieept withia aoaea of
diacharge:
(1) Tha atandarda contained in Sectiona 17-3.061(11
aad 17-3.071, F.A.C., apply to all watere of thia
(2) Tha atandarda contained in Sectiona 17-3.101,
F.A.C., apply to watara of thia claaaificatton which are
usad for or can reaaooably ba axpeetad to ba osad lor a
potable aupply.
Amkmkf 40L0(1. 401.0(1 40aJMT. 40$M4. 40( 704. 40M04 PS.
Uw !¦>!!¦ Illii 401 Oil. 4014(1, 401007. 400.001 401141. 401101,
4M.1M, 401(01 401701 401700. P& HlMry-N«r M-7«.
17-3.16 Draiaago Walla, DrOUag Beqalreawnte.
( Amlnrtl) 40»M1 P& Uw '-r1 n' 4MM1. 4010(1.4011M
PS. HiMocy-PanMrtjr M.»ll S-I-Tl
17-3.161 Claaaified Watara.
(11 The aurfaca watara of the State of Florida are
elaaaifiad by river baaina or aub-haaina aa Claaa III —
Reereatioa Propagation and Management of Fiah aad
WOdHfe, with only the individual exception* to Claaa III
liatod within each baaia aa delineated on USGS Map.
"Drainage Baaiaa ia Florida", Map Seriea No. 88, October
1967. Ont at ending Florida Watara ara liated ia Sectioa
17-8.041, Florida Adminiatrative Coda. An eecondary aad
tertiary canala wholly withia agricultural area* are hereby
claaaified as Claaa IV, and are not Uated below.
Agricultural araaa ahall generally include laada aetivaly
usad aoNy for the production of food aad fiber which are
coaed for agricultural uee where county aooing ia in effect-
Agricultural araaa exclude land* which are platted and
subdivided or in a tranaitioo phaae to residential uee.
(t) Tha groundwatara of the State of Florida are
claaaified on the baaia of total diaaolvad aolids content.
Groundwatara with levela of total diaaolvad aolids leas
than 10,000 milligrama per liter are claaaified aa Clase I-B,
and groundwatara with naturally-occurring levela of total
diaaolvad aolida equal to or greater than 10.000 milligrama
per liter are claaaified aa Ckaa V-B. These watere are aot
liated below.
(3) Florida Water Claeaificationa.
la) Naaaau — St. Marye Baain (No. 19). Thia baaia
coaaiata of U.S. Geological Survey Basins 09J (St. Marya
River Basin and coaatal area) and 09D (Coastal area
between St. Marya River and St. Johns River), and lie
wholly or partially in the following counties: Naaaau,
Baker, Columbia, Union and Duval (Con aolida ted City of
Jackaonville). The following individual waters are
exooptiona to Claaa III:
1. Naaaau County. South Amelia River — Naaaau
River north to Harriaon Creek — Claaa II. Alligator Creak
- Claaa II.
2. Naaeau County and Duval County. Naaeau River
and Creek — Naaeau Souad to Seymore Point — Claaa II.
3. Duval County (Coaaolidated City of
Jeckaonville). Pumpkinhill Creek — Claaa II. Intracoaetal
Waterway and tributaries — confluence of Naaaau and
Amelia Rivera aouth to Flaahiag Marker "72". thence
eaatward along Ft. George River to Ft. George Inlet and
includes Garden Creek and both prongs of Simpson Creek
4-187
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Supp. No. 114
WATER QUALITY STANDARDS
CHAPTER 17-3
- Claaa II.
(b) St. Johns Basin (No. 20). This basin consists of
U.S. Geological Survey Btsins 09E (St. Johns River basin
and Axb-beainel
-------
CHAPTER 174
WATER QUALITY STANDARDS
8»PP. N». 114
water, thence to the rear range markar of Cut "D"
northerly aioac the Una of Cut "D" rang* to a point ooe-
half nautical nil* taurid* tha southern boundary of Cut
"C", thence aloof a Una one-half mile inside and perallal to
Cut "C". Cut "D". and Cut "E" to a point with Latitude
27* 48*40* N. and Longitiid* 82*30'40* waat, thane* to a
point Latitude 27*47' north and 82*27' weet.
thanca on a trua bearing of 140* to tha Una of maan high
watar. thanca *'.jng tha Una of aaan Ugh water to tha
woatern tip of Mangrova Point, thanca to tha
oorthwaatarn tip of Tropical I aland, thanca aaatward
along tha Una of maan high watar to tha anatara tip of
Goat I aland, thanca dua aouth to tha Una of maan high
watar, thanca along tha Una of maan high watar to tha
point of beginning — Claaa II. Tamp* Bay —
Hfflsborough County portion waat of tha Sunahins
Skyway and fawn tha three fathom dapth contour up to
tha lino of maan high watar — Claaa II. Hillaborough
Rivar — City of Tampa Watar Traatmant Plant Dam to
Flint Craak - Claaa I-A. Cow Houae Creek —
Hillaborough Rivar to aourca — Claaa I-A.
4. Manatee County. Ten* Cain Bay — To Terra
Cain Point — Claaa II. Palma Sola Bay — Claaa II.
Paaeag* Kay Aran — Egmont Kay to Anna Maria laland
— Claaa II. Saraaota Bay — Eaat-waat Una through
marker "48" on Intraeoaatal Watarway aouth to Manataa
County Una — Claaa II. Manataa Rivar — Rya Bridge
Road to Bothany Vicinity — Claaa I-A. Ward Laka — SR
70 to aourca (SR 676) - Claaa I-A.
6. Saraaota County. Saraaota Bay — Waat of
Cantar (Intraeoaatal Watarway) — Claaa II. Lemon Bay —
Forkad Craak aouth to Charlotta County Una — Claaa II.
6. Charlotte County. Lemon Bay and Tributariee —
N. Charlotta County Una aouth to Pladda Harbor and
boundad oa tha aaat by SR 775 — Claaa II. Placida Harbor
— to maan high watar — Claaa II. OaqsoriUa Sound —
Placida Harbor to Charlotta County Una — Claaa II. Bull
Bay — maan high watar to Charlotta County Una — Claaa
II. Turtla Bay — maan high watar to Charlotte County
Lin* - Claaa II. Charlotta Harbor — Portion in USG8
Baain 10F aouth to Charlotta County Lin* — Claaa II.
7. La* County. Charlotte Harbor — Portion in
USG8 Baain 10F aouth from N. La* County Lin* — Claaa
II.
(g) PaacaBaain
-------
Sugg.
No 114
WATER QUALITY STANDARDS
CHAPTER 17-3
Okeechobee and the Everglades and lie* wholly or
partially in the following counties: Charlotte. Glades, Lee.
Hendry, Collier, Monroe. Dade. Broward, Palm Beach.
Martin. St. Lucie, and Okeechobee. The following
individual waters are exceptions to Class III:
1. Lee County. Caloosahatchee River — E. Lee
County Line to South Florida Water Management
District Structure 79 — Claee I-A. San Carlos Bay —
Portion in USGS Sub-basin 10B2 — Class II. Matanzas
Paaa — San Carloa Bay to Estero Bay — Class 11. Hell
Peckish Bay — Class II.
2. Collier County. Cocohatchee River — Claee II.
Little Hickory Bay — Class II. Wiggins Pass — Class II.
Inner and Outer Clam Bay — Class II. Inner and Outer
Doctors Bay — Class II. Connecting Waterways -
Wiggins Pass south to Outer Doctors Bay — Class II.
Naples Bay — Class II. Dollar Bay — Class It. Tidal Bays
and Passes — Rookery Bay south and easterly through
Ten Thousand Islands to Monroe County Line — Class II.
3. Monroe County. Monroe County Coastline —
North Monroe County Line south and including Florida
Bay within Everglades Nstionsl Park — Class II.
4. Dade County. Miami River — Salinity barrier
easterly 5.7 miles to Bisesyne Bay — Class IV.
5. Broward County. Abandoned Rock Pit —
Northeast corner of SR 7 and Prospect Field Road in the
S.W. Quarter of Section 7, T. 49 S., R. 42 E. — Class 1-A.
6. Palm Beach County. M- Canal L-8 to Lake
Mangonia — Class I-A. Lake Mangonia — Class I-A. Clear
Lake — Class I-A. Canal C-18 (freshwater portion) - Class
1-A. Canal C-18 — Salinity barrier to Loxahatchee River
— Class 11.
7. Palm Beach County and Martin County.
Loxahatchee River — Above Florida East Coast Railroad
Bridge including South. Northwest, and North Forks —
Class II.
8. Martin County. Grest Pocket — St. Lucie River
to Peek's Lake — Class II.
9. Multi County. Lake Okeechobee — Class I-A.
(k) Apalachicola Basin (No. 31). This basin consists
of U.S. Geological Survey Basins UE (Apalachicola River
Basin) and Sub-basins 11E2 (Chattahoochee River below
Mulberry Creek), 11E7 (Apalachicola River) and 11E8
(Chipola River), and lies wholly or partially in the
following countiee: Jackson. Gadsden. Washington. Bsy.
Calhoun. Liberty. Gulf, and Franklin. The following
individual waters are exceptions to — Claas III:
1. Gadsden County. Moequito Creek — U.S.
Highway 90 north to Florida State Line — Class I-A.
2. Franklin County. East Bay — Portion in USGS
Sub-basin UE7 with exception of area encompassed
within 2-mile radius from Apslachicola entrance of John
Gorrie Memorial Bridge — Class 11. Apalachicola Bay —
Portion in USGS Sub-basin UE7 with exception of erea
encompassed within 2-mile radius of John Gorrie
Memorial Bridge — Class II.
(1) Choctawhatchee Basin (No. 32). This basin
consists of U.S. Geological Survey Baains UF — Coastal
Area between Apalachicola River and Choctawhatchee
River. 12A — Choctawhatchee River Baain. 12B —
Coastal area between Choctawhatchee River and Yellow
River and Sub-basins 12A3 — Psa River end 12A4 —
Choctawhatchee River below Pes River, and lies wholly or
partially in the following countiee: Jackson. Calhoun.
Gulf, Franklin. Holmes. Washington, Buy. Walton.
Okaloosa. Santa Rosa, and Escambia. Ttie following
individual waters are exceptions to — Class 111:
1. Jeckson County Wsshington County, and Bay
County. Econfina Creek — Deer Point Impoundment to
source — Class l.A.
2. Gulf County. Indian Lagoon — West of Indian
Pass and St. Vincent Sound — Class II. St. Joseph Bay ~
South and weet of a line from St. Joseph Point to vicinity
Port St. Joe — Claas U.
3. Franklin County. St. George Sound (Portion of
USGS Basin UF) — East Pass to Apalachicola Bay —
Claas II. Apalachicola Bay — Portion in USGS Basin UF
with exception of area encompassed within 2-mile radius
from Apslachicola entrance of John Gorrie Memorial
Bridge — Class II. St. Vincent Sound — Apalachicola Bay
to Indian Paas — Class II.
4. Bay County. Eaat Bay and Tributaries — East of
U.S. Highway 98 to. but excluding. Wetappo Creek —
Claas 11. North Bay and Tributaries — North of U.S.
Highway 98 to Deer Point Dam excluding Alligator and
Fanning Bayous — Class II. West Bay and Tributaries —
West of North Bay (lins from Wsst Bay Point on the north
to Shell Point on the south) sxcept West Bay Creek
(northwest of Channel Marker 27C off Goose Point).
Crooked Creek (north of a line from Crooked Creek point
to Doyle Point), and Burnt Mill Creek (north of a line from
Graze Point to Cedar Point) — Class II. Daer Point
Impoundment — Dam to source — Claas I-A. Bayou
George and Creak — Impoundment to source — Class 1-A.
Beer Creek Impoundment to source — Class 1-A. Big
Cedar Creek — Impoundment to source — Class 1-A.
5. Walton County and Okaloosa County.
C hoc ta whs tehee Bay and Tributariea — Eastward from a
line from White Point southwesterly through Fl. Light
Marker "2" of the Intracoastal Waterway, and south of a
line from Alaqua Point to Wheeler Point, to the eastern
sources — Claas II.
6. Okaloosa County. Rocky Bayou —
Choctawhatchee Bay to Rocky Creek — Class II. Santa
Roea Sound — Okaloosa/Santa Roaa County Line east to
Manatee Point — Class II.
7. Okalooaa County, Santa Ross County, and
Escambia County. Santa Roea Sound — From a line
connecting Gulf Breeze approach to Penaacols Beach,
Bascule Bridge, and Sharp Point east to north — south
line through Manatee Point with exception of the Navarre
Beach area from Channel Marker "109" to Navarre
Bridge — Claaa II.
8. Santa Roea County. Blackwater Bay (Portion in
USGS Baain 12B) — From a line connecting Robinson's
Point to Broad River south to East Bay lline due west
from Eecriban Point) — Claas II. Eaat Bay and
Tributaries (Portion in USGS Basin 12B) — Blackwater
Bay (line due west from Escribano Point) southerly to
Peneacole Bay (line from Gercon Point on the North to
Redfish Point on the South) - Claas II.
(ml Perdido-Escambia Baain (No. 33). This baein
consists of U.S. Geological Survey Basins 12C (Yellow
River Basin), 12D (Blackwater River Basin and coastal
areal. 12E (Escambia River Baain and coastal aree). and
Sub-basins 12E1 (Conecuh River) and 12E4 (Escsmbis
River) and lies wholly or partially in the following
countiea: Walton, Okalooaa, Santa Roea. and Escambia.
The following individual waters are exceptiona to — Class
III:
1. Santa Roaa County. Blackwater Bay (Portion in
USGS Basins 12C sad 12D) — From a line connecting
Robinson's Point to Broad River south to F.ast Bay (line
due west from Escribano Pointi — Class 11. F.ast Bay
(portion in USGS Basin 121)) — Blackwater Hay 'lint* due
went from Escribano Point) — southerly to Pensarola Hay
lline from Garcon Point on the north to Kedfish Point on
the South) - Class II.
2. Santa Rosa County and Escsmbis County.
Escsmbis Bsy — Louisville end Nashville Railroad
4-190
-------
CHAPTBK174
WATBt QUALITY «T*m»n.
• No. 114
Traatia aouth to Panaarala Bar |Uh fcoaa ImmmI Point
Mat north—frty to Oareon Point) — Qaaol!. Pnaaaola
Bay — Eaat of a Um oonnactlnt lapiMi Mat oa tho
north to U» aouth and of tho Pfweoh Bay Bride* (U.S.
Highway 9t) — Claw IX. Saata Root Sound — Proa a Una
ronnacdng Gull Braaaa approach to flaaaacola Baach,
Baacula Bride*, aad Sharp Mat aaat to 8aata
Roaa/Okaloooa County Una with adaption of tho Navam
Baach aiaa fr «.t Chaoaal Marker "109" to Navam Baach
— Claaa II.
%mM« /mkmttf mm. mm mm. mM*. mm. mm rs.
um hvkMMt mm. *umi. mm. mm. «a*.i«i. 4aa.ui.
m.in. mm. «wt mm rs. ia—y n.» um ftmwdr
3M.I1. AM-71, MMB. W«
174.17 Drataac* Watt Ml Bawatlaa and
i hwtmitr mm ra. u» i«
n mwqr-li—1> M4.lt. la "
mi. win
174.18 Toot WaOa mi Borh^a.
mMi n, um i^iwmrt mm. mm i. «a».ioi.
4011*1 rn
. NMaqr—twmmiy IH.II.
174J9 Ahaadaaii Walla.
AmkmHf man rs u« ii
"" I I*. Bipwlii H-If.
HT».
401.011, 403.0(1 rs.
174J9 Mlatiaa aarvaya.
a>ietfl« Amkm*y mM\ rt Ln
«a»-iM rs. hmw-fii—h a
1401.011, 403.0*1, 403.101.
Htaurr-Porwriy SM.M, mt IUui—lnnd u
1T-4J4T.
174J1 OaaaWad Watara.
a»Minc Aedwrfcy «aijai ra. u» n< 4oa.aai. 40J.041 rs.
Hlxwy-Pw—1| H4il. Amm4tt 0-10-T1. 10-14-74. AnimiiJ aad
tlM«ltai< M IT4.iai. $-l-t9.
174*2 Application Porw.
aipMWc Awfcwin mttim ra. u* t iiataiu «oa.o«ifiM.
4amma rs. iihmj-N— *-n-n. to numm, i-ia-ra.
4-191
-------
RESPONSE HEC-2
The amount of sulfur dioxide emissions used in the ambient air quality analy-
sis is during worst case conditions and is considered to be very conservative.
Three methods will be utilized to regulate emissions: coal washing with up
to 25 percent reduction, lime/limestone scrubbing with up to 86 percent re-
duction, and sulfur content of raw coal. It can be seen that, should the
availability of low-sulfur coal dwindle, two other continuous reduction
methods are available to maintain maximum permitted emissions. It should
also be noted that this unit will be regulated under New Source Performance
Standards, which call for continuous monitoring of sulfur dioxide as well
as an overall 90 percent reduction of projected uncontrolled emissions.
RESPONSE HEC-3
The emissions data estimates in the DEIS have been misinterpreted by the
commentor. The uncontrolled fugitive dust emission rate of 900 tn/yr (which
actually should be 1200 tn/yr, see errata) is the emission rate which would
occur if no controls were applied. However, controls will be applied, re-
ducing the actual emission rate to about 120 tn/yr. Furthermore, this con-
trolled emission rate is for all four units, not just Unit 4. Therefore, the
projected total actual TSP emission rate from Unit 4 (with controls) equals
568 tn/yr (from the stack) plus approximately 1/4 of the 120 tn/yr from coal
handling for a total of 598 tn/yr. Also, the projected actual emission rate
from the stack of 568 tn/yr reflects a reduction of approximately 70 percent
from the emission rates of each of the existing units due to the current
stricter controls on TSP emissions from new facilities.
RESPONSE HEC-4
Analyses of precipitation over the last several decades have indicated that
the acidity of the precipitation has increased, principally in the eastern
United States and in western Europe. In the United States the problem of
acid rain (pH<5.6) has been particularly acute in the northeast. Research
conducted in Florida has shown the acidity of precipitation falling in the
State has also increased. Analyses have indicated that nearly all of the
acidity of precipitation falling in Florida is attributable to sulfuric and
nitric acids. Brezonik et al. (1980) reported the sulfuric acid component
of the acidity to be 2.0 to 2.5 times that of the nitric acid component.
Because of the complexity of air transport mechanisms and the chemical proc-
esses involved in acid rain formation, it is not known how specific sources
(e.g., Big Bend Unit 4) would affect the acidity of precipitation. It is
thought that power plant emissions (principally SO2) contribute to the acid
rain phenomenon. This was identified in the EIS.
As noted, the reported effects of acid rain include acidification of lakes
and rivers with the attendant impact to aquatic ecosystems, acidification
of ground water, acidification and release of metals from soils, deteriora-
tion of structures such as buildings, metals, and statuary and possible damage
to forests and agricultural crops.
4-192
-------
The USEPA is extensively involved in research and monitoring efforts to study
this globally significant problem* EPA has developed the coordinated Federal
monitoring program which is to support the nation's acid rain research initia-
tive. EPA in conjunction with the National Oceanic and Atmospheric Adminis-
tration (NOAA) is supporting the U.S. contribution to the global monitoring
network established by the World Meteorological Organization. EPA Environmen-
tal Research Laboratories and offices are currently directing or participating
in numerous acid rain related studies. These studies include investigations
into the effects of acid rain on vegetation, agricultural crops, aquatic
systems, health, air transport mechanisms, atmospheric and precipitation
chemistry and kinetics, aerosol formation and deposition, and related areas.
References
Air Pollution Control Association Presentation. 1980. Acid Rain: An
International Concern. Journal of the Air Pollution 'An™.-,*»
tion, 30(10): 1089. Oct^T. " A880cla-~
Brezonik, P. L., Hendry, C. D., Edgerton, E. S., Schultze, R. L., and
Chrisman, T. L. 1980. Acidity, Nutrients, and Minerals in Atmospheric
Precipitation over Florida: Deposition Patterns, Mechanisms, and
Ecological Effects. Completion Report to U.S. EPA for contract
#R-805560.
Likens, G. E., Wright, R., Galloway, J., and Butler, T. 1979. Acid Rain.
Scientific American, Volume 24, November 4. October.
U.S. Environmental Protection Agency. Acid Rain. October, 1979. Office
of Research and Development. EPA-600/8-79-'028.
U.S. Environmental Protection Agency. Acid Rain. July, 1980. Office
of Research and Development. EPA-600/9-79-036.
RESPONSE HEC-5
Results of studies on the distribution of benthic macrophytes in the Big Bend
area, including the Apollo Beach northern embayment, have been presented in
the DEIS (Section 3.3.1.4) and supporting TRD (Section 5-3.4.2).
these studies have only limited value as £ TZllrtT
impacts. Sipe et al. (1979) and Mangrove Systems, Inc. (1980), by comparing
If!. L. «,ri.l photography, have documented a significant.decrea.
impacts. Sipe et al. (1979) and Mangrove system*, ,7 '7^7"1°
historical maps and aerial photography, have documented a significant decrease
(up to 80 percent) in the distribution of benthic seagrasses withift Hillsborough
County since 1876. Mangrove Systems, Inc. (1980) suggested the decline was due
to a variety of causes including dredge and fill activities in conjunction with
y - - discharges, and water quality degradation. In
Inc. (1978, 1979; noted cnat,
¦unity in the embayment reprwent. a atreaaed ay.ten. .
of past dredging, solar heating, and thermal effluent on thia «"«ed sy.tM.
(of"thUdr't bTr°VofS»M«r«.arin
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the combined construction and operation activities of all dredged sites in the
area, including Port Redwing) Big Bend Units 1, 2, & 3; and the Apollo Beach
residential development."
While there is the potential for increased stress upon the seagrass/algal
and mangrove coomunities within the embayment from the additional thermal
load from Unit 4, there are no data to allow for differentiation from other
sources of impact to these communities. Studies conducted at Big Bend
(Mahadevan et al., 1977, 1980) have suggested that the extreme shallowness
(mean depth ~1 meter) and solar heating may be the most important factors
controlling water temperatures in the embayment. Water temperatures were
often greater in the embayment than occurred at the site of the discharge
of the plant thermal effluent. It may be possible to extend the sheet
pile wall. However, it has not been demonstrated that there is a problem
of thermal loading in the embayment area. 8e« also responses to written
comments CDC-3 and CDC-5.
RESPONSE HEC-6
Under present criteria of the Resource Conservation and Recovery Act (RCRA),
utility ash and FGD scrubber wastes are not designated as "haEardous" and
therefore do not require long-term closure plans. However, should these
wastes be reclassified, TECO is committed to fulfill all pertinent regula-
tions including those related to long-term maintenance of the disposal sites.
As proposed, the fly ash and FGD by-product waste are to be marketed. For
those wastes disposed onsite, a groundwater monitoring program to detect
contamination is to be implemented.
RESPONSE HEC-7
See response to transcript comnent GCR-13.
RESPONSE DOI-1
Deposits of phosphate, limestone and peat are actively mined in the Central
Florida region. The only impact of the project on these resources will be
the consumption of approximately 3.4 million tons of limestone by the FGD
system during the life of the plant. This limestone will come from mining
operations within the Central Florida region.
RESPONSE DOI-2
The recommendation of the Fish and Wildlife Service regarding the manatee
has been considered. Tampa Electric Company will close the boat ramp from
November 15 through March 30. Paragraph M of the NPDES permit Part III
NEPA conditions has been rewritten to reflect closure of the boat ramp
between these dates.
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RESPONSE CR-1
Comment acknowledged.
RESPONSE CR-2
Comment noted. Aa explained in Section 2.6 of the DEIS, onsite disposal of
fly aah and gypsum will be required only to the extent that these byproducts
are not marketable. TECO is now selling the fly ash from Units 1-3 and in-
tends to sell the gypsum as well.
RESPONSE CR-3
Comment acknowledged.
RESPONSE CR-4
Comment acknowledged.
RESPONSE CR-5
Comment acknowledged.
RESPONSE SC-1
EPA on numerous occasions has expressed reservations with the
modeling .ffort. pur.ued by TEOO for th« Big =
and D of th. Draft IIS contained »*'• ««*"**•
relative to th. Section 316 (a) 4 (b) a..oeiated .ith Big Bend Unit.
1-3 and Unit 4.
In T »ethod?log °< th* thiec^n"0ri'sed"«?rnotedPbuJ do Hot Re-
used m the Agency's findings, the comments
quire a response.
RESPONSE SC-2
See response to written consent SC-1.
RESPONSE SC-3
- t. uK- r-mmti for a discussion of the water
Cownents noted. The Draft EIS should be read tor
quality aspects of Unit 4.
RESPONSE SC-4
See response to written conment SC—1.
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RESPONSE SC-5
This comnent is addressed to the Florida Public Service Commission. EPA
does not have the expertise or jurisdiction to make decisions relative to
the need for power. See EPA's response to written comment SC-7 relating
to conservation.
RESPONSE SC-6
See response to written comment SC-7.
RESPONSE SC-7
The Council on Environmental Quality (CEQ) regulations for implementing
the National Environmental Policy Act (NEPA) (40 CFR 1500-1508) outline
the provisions by which Federal agencies are to comply with NEPA. The
CEQ regulations do identify alternatives evaluation as the heart of the
EIS (40 CFR 1502.14). The principal alternatives identified during the
scoping process were cooling water systems and air emissions control.
Additionally, in the Draft EIS, siting, wastewater treatment, solid waste
disposal, and electric generating (technologies and management) alterna-
tives were addressed. Conservation alternatives to Big Bend Unit 4 were
not raised during the scoping process. Consequently, this was not identi-
fied as a significant issue in the Draft EIS.
The language of 40 CFR 1502.16 is that the environmental consequences of
various alternatives shall include discissions of "(e) energy requirements
and conservation potential of various alternatives and mitigation measures."
All reasonable alternatives were presented and addressed in the Draft EIS
in accordance with the CEQ regulations (40 CFR 1502.14a).
The CEQ regulations allow for the incorporation by reference in the EIS of
reasonably available information (40 CFR 1502.23)* Additionally, Federal
agencies may cooperate with State and local agencies to eliminate duplica-
tion of effort in environmental assessments. The Florida Public Service
Commission had previously analysed the need-for-power question and had issued
an Order permitting construction of the new facility. These analyses and
decisions are primarily the responsibility of the Florida Public Service
Commission (FPSC). EPA's primary responsibility is to address the environ-
mental impacts of project alternatives. In fulfilling this responsibility
EPA may use the resources of other agencies.
In late 1980 the FPSC adopted rules 25-17.01 through 25-17.05, Florida Admin-
istrative Code, which established statewide energy conservation goals as re-
quired by the Florida Energy Efficiency and Conservation Act (FEECA). The
primary focus of these goals was directed toward the conservation potential
in the residential sector. FEECA directly addressed energy efforts toward
increasing the efficiency of Florida's electric generating system by reduc-
ing weather sensitive peak demand and kilowatt hour consumption.
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Attainment of the conservation goals would reduce the projected energy growth
in the peninsula from 4.3 percent to 2.6 percent for the period 1980 to 1989.
With respect to current expansion plans, the reserve margin for firm load for
the 1988/1989 winter peak would be 65.5 percent if the goals are achieved.
Elimination of proposed expansions would reduce the reserve margin to 33.7
percent in 1988/1989. A reserve margin of 20-30 percent for individual
utilities is considered adequate and reasonable. In addition, attainment
of these goals would reduce projected 1990 oil consumption for electrical
generation by 25 percent.
Based on this analysis, the FPSC stated in their Order (9749) that the
achievement of the conservation goals would eliminate the peninsula's need
for Big Bend Unit 4. However, the FPSC further stated that if the goals
were not achieved, additional generating capacity may be needed.
The FPSC also looked specifically at the projected electrical power needs
in the TECO service area. If the conservation goals are met in the TECO
service area and if Big Bend Unit 4 is not certified or is significantly
delayed, TECO reserve margins would drop to 21.3 percent for the winter
of 1985/1986 and to 11.7 percent for the winter of 1988/1989. Consequently,
the FPSC stated in their Order the need for additional capacity is apparent
in the TECO service area.
As noted, an element of the FEECA goals is to reduce the peninsula's depend-
ence on foreign oil. The FPSC stated in their Order that based on their
worst case analysis (construction cost overruns and delays) significant
economic benefits would result from construction of Big Bend Unit 4.
Approximately 3.9 million barrels of oil would be displaced annually and
could contribute approximately $232 million (1980 dollars) to reducing
Florida's dependence on imported oil.
An alternative to meeting the need for additional generating capacity is
purchase of power. The FPSC stated in their Order that such efforts have
been determined not to be cost or time effective on the basis of the eco-
nomics considered.
Based upon the testimony and evidence entered in the hearing record, the
FPSC stated in their Order that Big Bend Unit 4 is needed and should be
approved. No evidence was presented in the hearing record regarding the
inadequacy of the conservation analysis. No evidence was presented on this
issue during the States administrative hearing for determining whether the
power plant siting application for Unit 4 should be granted.
EPA, in preparing the Draft EIS considered the analysis of the FPSC. Based
upon this analysis and EPA's review, consideration of conservation efforts
was an element of the FPSC decision. Consequently, a specific independent
reassessment of the conservation alternative was not undertaken particularly
since this issue was not identified during scoping.
Conservation measures including installation of energy efficient appliances
and energy auditing and loan programs sponsored by the utility for such
measures as solar hot water heaters, heat pumps, or weatherization have
been effectively used in other areas. While it may be possible to project
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the degree of conservation possible if all consumers utilize the most energy-
efficient home features and appliances, a study of this magnitude is outside
the scope of this EIS. The conservation program established by 7EECA was
identified as being reasonable and achievable.
EPA Region IV has contacted EPA Regions VIII and IX and the Bureau of Land
Management (BLM) regarding the 2500 MW Allen-Warner Valley project. The
sponsoring parties for this project were two California utilities and a
Nevada utility. Regions VIII and IX were involved as reviewing agencies
under Section 309 of the Clean Air Act and as the PSD permit issuing entities.
The Warner Valley plant is in Utah (Region VIII). The Allen plant is in
Nevada (Region IX).
In their analysis the California Public Utilities Commission (CPUC) indicated
that if there was continued implementation of energy goals (through conserva-
tion, renewable resources, solar), the California utilities would not need
the additional generating capacity projected for 1989. Subsequently, the
California utilities withdrew from the project. The BLM's final recommenda-
tion was to permit the Nevada utility's construction of a 2000 MW Allen plant.
EPA Region VIII proposed to deny the PSD permit for the Warner Valley plant
in Utah because of air quality issues. Neither Region VIII nor Region IX
specifically endorsed the Willey model used in the Environmental Defense
Fund's analysis of conservation. Based on the CPUC analysis, EPA indicated
its preferred alternative to be conservation. Current plans by the utili-
ties are to proceed with 2000 MW of the originally proposed 2500 MW.
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4.2 TRANSCRIPT OF PUBLIC HEARING ON DEIS AND RESPONSES TO TRANSCRIPT COMMENTS
Individual comments made during the Public Hearing on the Big Bend Unit 4
DEIS have been identified by an alphanumeric deaignation that is marked in
the margin of the tranicript.
Responses to theae comments appear at the end of this section.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region IV
FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION
A PUBLIC INFORMATION HEARING IN RE:
TAMPA ELECTRIC COMPANY
Draft Environmental Impact Statement; Notice of
Proposed Issuance of National Pollutant Discharge
Elimination System Permit; Notice of Preliminary
Determinations Regarding Prevention of Significant
Deterioration; Tentative Findings under Sections
316(a) and (b); Proposed Net Limitations for Slag
Pond Effluent; Notice of Consideration for State
Certification of the NPDES Permit
Units 1, 2, 3
Proposed Unit 4
Big Bend Station
Time: 7:30 p.m.
Date: August 19, 1981
Location: Recreation Center
901 6th Street
Ruskln, Florida
REPORTING: ANNE JAPOUR, CVR
BAY PARK REPORTING COMPANY
COURT REPORTING
33 FOURTH STREET NORTH
ST. PETERSBURG. FLORIDA 33701
(813) 823-8381
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ENVIRONMENTAL PROTECTION AGENCY:
HOWARD D. ZELLER, Acting Director
Enforcement Division
Atlanta, Georgia
1
DARIO DAL SANTO, Project Officer
Environmental Impact Statement Branch
Atlanta, Georgia
p. 10
CHARLES KAPLAN,
Chief, Power Plant and Synfuel Unit
Enforcement Division
Atlanta, Georgia
p. 14
DELBERT HICKS
Senior Aquatic Biologist
Surveillance and Analysis Division
Athens, Georgia
p. 19
FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION:
HAMILTON S. OVEN, JR.
Administrator of Power Plant Siting
SPEAKERS:
HEYWOOD A. TURNER
Senior Vice-President/Production
Tampa Electric Company
p. 25
GLORIA RAINS
Manasota-88
p. 35
SALLY THOMPSON
Hillsborough Environmental Coalition
p. 43 !
RICHARD T. PAUL
Hillsborough Environmental Coalition
p. 44
BAY PARK REPORTING COMPANY
cotui rii'orriN<;
It IOIJKTH STRIiKT NORTH
sr. i-i 11 rsbi;r(;. r.orida )17oi
(XU) HJI-HIHS
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2A
SPEAKERS (Cont'd.)
MICHAEL KENNEY
Hillsborough Environmental Coalition p. 47
LAURIE MACDONALD RASK
Tampa Bay Sierra Club p. 50
JULIE MORRIS
Florida Sierra Club p. 51
BARNEY CAPEHART
Florida Sierra Club p. 55
BAY PARK REPORTING COMPANY
COURT REPORTING
33 FOURTH STREET NORTH
ST. PETERSBURG. FLORIDA 3J701
(111) 13). mi
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PROCEEDINGS
(Whereupon, at 7:30 p.m. the
public hearing was called to order)
MR. ZELLER:
Well, it's 7:30, and I think I'd like to convene i
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the hearing. If anyone comes in later than this, they'll have !
an opportunity to register and still be able to participate. !
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We have a rather lengthy agenda of items to cover I
as far as the hearing is concerned, so I think it's time to --
time that we begin and get under way.
My name is Howard Zeller, ladies and gentlemen, and
I'm the Acting Director of the Enforcement Division for the
United States Environmental Protection Agency in Atlanta,
Georgia.
With me this evening is Mr. Hamilton Oven, Buck
Oven, who represents the Florida Department of Environmental
Regulation, and there are a number of other EPA people whose
i
names you see on the agenda that was handed out to you at the j
time you registered.
The hearing tonight will address the possible actions
3y EPA with respect to Tampa Electric Company's Big Bend station
I
lear Tampa in Hillsborough County, Florida. i
EPA is at this time considering the reissuance of a
jermit for existing Units 1 through 3 and the issuance of a
>ermit for the first time for a proposed Big Bend Unit 4.
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The hearing is for the purpose of receiving comment
>n the Draft Environmental Impact Statement, the proposed re-
.ssuanee and issuance of a National Pollutant Discharge Elimina
:ion System permit and consideration for State certification
>f the permit.
Under Section 401 of the Clean Water Act, the
State of Florida has been requested to certify the proposed
gPDES permit will not cause violations of Florida Water Quality
Standards.
The Federal Water Pollution Control Act, which is
commonly referred to as the Clean Water Act, has as its ex-
plicit goal elimination of the discharge of pollutants by 1985.
To achieve the goal, the Act has created the National Pollutant
Discharge Elimination System or NPDES, which is a national
permit program, to control the discharge of pollutants into
the nation's waters.
Under the permit program, anyone who proposes to
discharge wastes into the waters of the United States must
receive a permit setting limits and conditions on the discharge
of pollutants. The Act places technology-based limitations on
existing discharges designed on an industry-by-industry basis.
The NPDES permit is the basic regulatory tool for
water pollution abatement under the federal law. This discharg
must be in compliance with its permit effluent limits upon
initiation of its discharge. Any violation of the terms, the
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limits, or violations of tie permit will subject the discharger
to civil or criminal penalties.
Now, due to the aforementioned administrative pro-
cedures required for existing sources — that is, Units 1 and(s
3 — and the new source, Unit 4, there were separate applica-
tions submitted to EPA, and there are separate application
numbers; all of that information is available to you on your
fact sheet.
However, we do not intend to issue two permits as
far as the Big Bend station is concerned. We will issue only
one permit after completion of the Environmental Impact assess-
ment procedures that are applicable to the new source; that is,
Unit No. 4.
Based upon initial evaluation of applicable stan-
dards of performance for new sources and Florida Water Quality
Standards' requirements, EPA notified the applicant -- that is,
Tampa Electric Company -- that offstream cooling would be
required for Unit No. 4. However, following a request for
alternative limitations, which are allowed under Seption 316
of the Federal Water Pollution Control Act, EPA has tentatively
determination -- determined that once-through cooling is
acceptable provided that the applicant installs fine-mesh
screens on the intake structures for Units 3 and 4 to prevent
any increase in the entrainment of marine organisms.
I
The Draft NPDES permit proposed for Big Bend
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itation was prepares by the staff of Region IV, EPA, using
ipplicable guidelines and standards for the steam electric
>ower generating point source category and the Florida Water
Quality Standards' requirements.
We made available for distribution this evening
:opies of the public notice and the fact sheet. A few copies
Df the Draft Environmental Impact Statement are available also.
Each of these documents, as well as other relevant documentatloi
and all comments received tonight or submitted in writing by
December 2nd(sic), 1981, will become a part of the administra-
tive record of this hearing.
The information in the record will be used in
evaluating the Draft permit and either preparing a final NPDES
permit or denying the applicant a permit for the existing and/oi
proposed discharges.
Permit issuance would occur after release of the
final Environmental Impact Statement.
Now, in addition, you should be aware that all
public comments on the TECO Big Bend facility and the Draft
EIS, whether received here tonight and transcribed for the
record or submitted in writing directly to EPA, will be sum-
marized, and all of these issues will be addressed in the final
Environmental Impact Statement.
A copy of the proposed permit will also be included.
in the final Environmental Impact Statement.
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N.iw, a permit, under the Prevention of Significant
Deterioration program of the Clean Air Act, will also be re-
quired for Big Bend Unit 4. A revised preliminary determina-
tion with regard to that permit was published with the Draft
Environmental Impact Statement. The comment period on that
permit closes on September 2nd, 1981, after which time a final
determination may be issued.
This hearing is an EPA public information hearing,
and it's conducted pursuant to 40 CFR 124.42(b) of our regula-
tions. Notice of the public hearing was published in the
Sarasota Herald Tribune and the Tampa Tribune on July 16th,
1981. Additionally, copies of the public notice were mailed to
all individuals and organizations on EPA's mailing list in
Florida and to all appropriate government agencies. A copy
was posted in the Ruskin Post Office for thirty days.
At this time I'd like to ask Hamilton Oven, Florida
Department of Environmental Regulation, to make any comments
he has concerning the 401 certification.
I
Mr. Oven?
MR. OVEN:
Thank you, Mr. Zeller. j
My name is Hamilton S. Oven, Jr. I'm the Admini- I
strator of Power Plant Siting for the Florida Department of
Environmental Regulation. As such, it's been my duty to review1
an application made to the State of Florida for certification
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pursuant to Florida law.
The Power Plant Site Certification program is a
one-stop permitting process, which encompasses all State permitb
As such, we have reviewed the water quality aspects. We have
coordinated our conditions of certification with EPA in order
that a valid 401 certification can be issued.
In reviewing the application, we noted that due to
ambient conditions in Tampa Bay, there will be certain occasion
when Tampa Electric Company would not be able to comply with
the Florida Water Quality Standards.
Tampa Electric Company then applied for a variance
to Florida Water Quality Standards. Their request was con-
sidered at a certification hearing held in Tampa on June 23rd,
1981. The Hearing Officer took the recommendation of Tampa
Electric Company and the Department under advisement and recom-
mended to the Governor and Cabinet that this variance be
granted, and that variance was approved by the Governor and
Cabinet when they approved the certification of the power plant
on August 4th of 1981.
So with that, the Department would be able to
certify to the 401 compliance. The Department also reviewed
the 316(a) and 316(b) provisions of Public Law 92-500. We
concurred with EPA that the use of fine-mesh screens on Units
3 and 4 would solve the problem and meet the Best Available
Technology as far as the issue of excessive entrainment
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was concerned. The Department was somewhat uncertain of whethe
or not that the data provided from Tampa Electric Company
satisfied all of our requirements as far as 316(a). We've
addressed that in our conditions of certification by requiring
a better model to determine the size of a thermal mixing zone
and also some additional biological studies.
The Department also will be submitting a certifica-
tion under 40l and Section 404, United States Army Corps of
Engineers, as far as some of the dredging activities associated
with the power plant.
We concurred with EPA as far as the PSD and BACT
provisions of the Clean Air Act are concerned.
The State of Florida has certified Tampa Electric
Big Bend 4. The State of Florida has also considered the
variance request for Units 1, 2, and 3. A Hearing Officer's
report recommending that variance be granted has been received
by the Department. It is being processed by the Department;
it's anticipated within the next couple of weeks that that
variance for Units 1, 2, and 3 will also be approved.
MR. ZELLER:
Thank you, Mr. Oven.
Let me — Let me correct something for the record.
(Is. Hanson just pointed out to me that I erroneously stated on
the — based on the hearing record, that it would be closed on
December 2nd. That should be, of course, be September 2nd, so
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please correct the record accordingly.
Next I'd like to ask Mr. Darlo Dal Santo with the
Environmental Protection Agency to please come forward. Mr.
Dal Santo is with the Environmental Impact Statement Branch.
He's been Project Officer on this project for a number of years
and will give you some background information relative to the
E1S process and the National Environmental Policy Act.
Mr. Dal Santo?
MR. DAL SANTO:
Thank you., Mr. Zeller.
Good evening. I am Dario Dal Santo, and I've been
the Project Officer for the Environmental Impact Statement on
the Tampa Electric Company's proposed Big Bend Unit 4 complex.
The proposed unit will have a net generating
capacity of 417 megawatts and will be located at the existing
Big Bend complex along Hillsborough Bay in Hillsborough County,
Florida.
What I would like to do this evening is briefly
outline the NEPA process and the EIS process without going into
details of the Environmental Impact Statement.
Under provisions of the National Environment Policy
Act of 1969, which we call NEPA, an Environmental Impact
Statement, which we designate as an EIS, must be prepared for
all major federal actions which may significantly affect the
quality of the human environment. |
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Operation of Big Bend Unit 4 would require a
National Pollutant Discharge Elimination System permit. As
Mr. Zeller said, this is the NPDES permit.
The EPA Region IV Administrator had determined that
the proposed Unit 4 would be a new source, as defined by Sectio|i
306 of the Clean Water Act, and issuance of a new source NPDES
permit is a major federal action significantly affecting the
quality of the1 human environment and, therefore, is subject
to the provisions of NEPA.
Consequently, the EIS has been prepared, and notice
of its availability was published in the Federal Register,
Volume 46, on July 17, 1981.
The purpose of the EIS is to provide government
agencies and the public with information to assure that an
appropriate and thorough review of the environmental impacts
of a proposed action are included in the decision-making proces
The EIS was prepared using the third-party EIS
process. Under this arrangement, Tampa Electric Company retainle<
a consultant to prepare the EIS, subject to EPA guidance and
direction.
NUS Corporation was nominated by Tampa Electric
Company, and EPA approved this nomination. However, the ultimate
responsibility for the EIS remains with EPA.
In accordance with the Council of Environmental
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Juality guidelines for implementing the National Environmental j
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Policy Act, the Draft EIS emphasizes the principal issues,
alternatives, and impacts associated with the proposed project.
Accompanying the Draft EIS are two technical suppor
documents or technical reference documents, which contain the
detailed analyses that were used in the preparation of the
summary document.. This is consistent with CEQ guidelines.
The CEQ guidelines specify that an EIS should focus
on the major issues associated with the proposed project and
that less emphasis in the EIS should be devoted to less import-
ant issues.
The major issues associated with the proposed Big
Bend project included cooling water system alternatives and air
emissions control. Other systems of alternatives addressed in
the EIS included siting, wastewater treatment, residual waste
disposal, and electric generating management.
Several measures, which would mitigate the environ-
mental impacts of the proposed project, were identified during
preparation of the EIS, and these measures were made conditions
of the NFDES permit that is proposed, tentatively proposed, to
be issued, and include: implementation of a groundwater moni-
toring program for the assessment of leachates from coal pile,
wastewater treatment areas, and residual waste disposal areas;
implementation of a construction erosion and sedimentation
control program; implementation of a biological monitoring
program to fully evaluate survivability of organisms in the
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fine-mesh screens and the organism return mechanism and on the
benthos of Tampa Bay; preservation of a mangrove swamp along
the southwestern coastal portion of the Big Bend complex; and
posting of signs in the discharge canal to warn boaters of
the presence of the West Indian Manatee, which is an endangere(
species.
Any comments you may have on the Draft EIS or the
permitting decision will be appreciated. Comments should be
forwarded to Mr. John E. Hagan of EPA, Region IV, at the
address listed at the bottom of the agenda.
As noted, the comment period will remain open
through the 2nd of December — 2nd of September. Excuse me.
MR. ZELLER:
Not you, too.
(Laughter)
MR. DAL SANTO:
A final EIS will be published after close of the
comment period. The final EIS will consist of the Agency's
statement of findings, tentative permit decisions, substantive
comments on the Draft EIS, and responses to the comments,
transcript of this hearing, and any additional evaluations
performed since publication of the Draft EIS.
If you wish to retain a complete evaluation of the
project, you should keep a copy of the Draft EIS, since we will
I
not republish verbatim the contents of the Draft EIS.
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Thank you.
MR. ZELLER:
Thank you, Mr. Dal Santo.
Next I'd like to ask Charles Kaplan to make a brief
statement relative to the NPDES permit; Mr. Kaplan, who's Chief
of our unit that handles power plant permits and synthetic fuel
permits.
Mr. Kaplan?
MR. KAPLAN:
Thank you, Mr. Zeller.
Good evening, ladies and gentlemen. My name is
Charles Kaplan. I'm employed by the U.S. Environmental Protec-
tion Agency as Chief of the Power Plant and Synfuel Unit in
the Enforcement Division for Region IV office. I'm headquarter|e<
in Atlanta, Georgia.
It is my principal responsibility to draft National
Pollutant Discharge Elimination System permits for power plants
in the Region IV area. For brevity, we usually speak of these
as NPDES permits.
At the registration desk there ace copies of both
the public notice and the fact sheet for the facility. The fac
sheet contains the proposed effluent limitations and special
requirements as well as the permit rationale for the Big Bend
station NPDES permit. The draft NPDES permit and rationale are
also included in the Draft Environmental Impact Statement.
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As Mr. Zeller has previously indicated, EP/ is pro-
posing to grant an NPDES permit to TECO for its wastewater dis-
charges from the existing three units and the proposed Unit 4
at the Big Bend station.
The application for the existing units describes
six discharges to the plant intake and discharge canals, and
the application for Unit 4, which proposes six additional dis-
charges also tot these same canals. All twelve discharges
ultimately enter Hillsborough Bay.
Under the provisions of the Clean Water Act, a
liquid waste discharge from a steam electric generating facility
to waters of the United States must meet two different sets of
criteria.
The first is that the effluent must meet the re-
quirements of the Effluent Guidelines and Standards for the
Steam Electric Point Source Power Generating Category. These
*ere promulgated on October 8th, 1974. They're contained in
ritle 40, Part 423, of the Code of Federal Regulations.
In effect, this first set of criteria requires the
ipplicant to provide a base level of treatment technology which
.s required for all similar steam-electric generating facilities
The second requirement is that the discharges, in-
lividually or in conjunction with other discharges into the
arious receiving waters, must not violate the Florida Water
uality Standards. This requirement provides for inclusion of
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more sophisticated treatment technology as necessary to protect:
the water quality of the receiving water body. These are
determined by criteria adopted by the State of Florida.
In addition to the two sets of criteria I've indi-
cated, EPA proposed certain amendments to the steam-electric
guidelines in October 1980. This proposal addressed both toxic
pollutants and what are called priority pollutants.
Application of all these requirements to both the
existing and the proposed discharges from the Big Bend station
is in the form of effluent limitations and special conditions,
which I've indicated are included in the Draft permit and
described in the fact sheet.
The Draft permit contains limitations on the amount
of pollutants, such as total suspended solids, oil and grease,
total residual oxidants and heat, which may be discharged.
The fact sheet contains copies of the proposed
effluent limitations and the special conditions which are
designed to assure that construction of Unit 4 and operation of
all four units is done in an environmentally-acceptable manner.
As stated in the public notice, all pollutant
limitations and other permit conditions are tentative and still
open to comment.through September 2nd.
In reviewing the application for the Big Bend
station, two unusual situations were presented. Both are due tc
high levels of ambient pollutants present in Hillsborough Bay
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waters. Bay water is used for sluicing t.ae ash slag to the
settling pond for the three existing units. On occasion, high
background levels of total suspended solids are carried into
the pond, and some continue out the effluent. Therefore, an
evaluation of intake and effluent solids, as well as heavy
metal concentrations, was undertaken. This evaluation has led
EPA to propose effluent limitations which would allow a credit
for carry-over of solids present as the background in the
intake water.
The second situation was a result of the various
heavy metals in Che ambient intake water in concentrations
which already exceed levels prescribed by the Florida Water
Quality Standards.
Use of bay water for ash sluicing results in a
small addition of the various heavy metals to the effluent,
particularly arsenic, chromium, iron, and selenium. Small
additions can also be expected from some of the Unit 4 dis-
charges .
Since the ambient levels are already high, either
additional treatment would be required or a variance to the
Water Quality Standards would be necessary for the effluents
from the Big Bend station to be in compliance with the Florida
Water Quality Standards.
As Hr. Oven has indicated earlier, the State of
Florida has granted a variance to TECO for the Unit 4 discharge
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for a two-year period. Further, tl'e State has proposed a two-
year variance for the ash -- slag pond effluent for the existing
units.
During this two-year period, additional monitoring
is to be required, as well as an evaluation of the available
treatment technologies to reduce the level of pollutants dis-
charged from the slag pond and the other sources from Unit 4.
As I close, I wish to indicate that EPA is presently
reviewing these variances, proposed variances, to the standards
and our concurrence or our evaluation will be included in the
final Environmental Impact Statement.
Thank you very much for your attention.
MR. ZELLER:
Thank you, Mr. Kaplan.
The final speaker on the agenda for the Environment^
Protection Agency is Delbert Hicks. Mr. Hicks is an aquatic
biologist, and he will address those functions of 316(a) and
316(b), which 1 mentioned earlier, which generally deal with
thermal discharges from the power plant as well as what impact
the entrainment of organisms may have on the intake structure.
Mr. Hicks?
MR. HICKS:
Thank you.
For the record, my name is Delbert B. Hicks. I'm
employed as a senior aquatic biologist with the Environmental
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Protection Agency. I'm assigned to the Surveillance and
Analysis Division, stationed in Athens, Georgia.
My purpose tonight is to provide a brief overview
of the historical assessments that have accompanied the growth
of the Big Bend facility over the last six or seven years.
My technical involvement with the Big Bend facility
dates back to 1973 when the Tampa Electric Company was planning
construction of Unit 3. In May 1976, Unit 3 was placed into
operation, but prior to this date, the company initiated
technical studies to evaluate the environmental impacts associ-
ated with the operation of Units 1, 2, and 3 at the Big Bend
site.
These units employed a dilution assist, once-throug
cooling system, ihat was viewed as rather unique for this
particular area.
The studies commenced in January 1976 and continued
through March 1977. The results of these efforts were published
by TECO in September 1977 and provided to the Regional Admini-
strator of Region IV for evaluation.
Based on the technical facts presented, the Regional
administrator determined that the thermal discharge from the
:ombined Units 1, 2, and 3, with the benefits of a dilution
issist cooling system, was not causing an unacceptable adverse
mpact to Hillsborough Bay and Tampa Bay .
However, the Regional Administrator further
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determined that the legation and the capacity of the cooling
water intake structure, including the dilution pump system,
was a major factor causing an unacceptable level of entrainment
and therefore failed to reflect the best technology available
for minimizing adverse environmental impacts.
And for those of you who are not familiar with the
concept of entrainment, we're speaking of a consumptive process
that removes biological properties from the water; that is, the
eggs, the larvae^ ike fish and shellfish.
The Tampa Electric Company responded to the above
determination by the Regional Administrator with a proposal to
terminate the use of the dilution assist cooling system and
provide for studies to assess the biological and associated
thermal consequences of such an action.
Retirement of the dilution system would reduce the
withdrawal capacity of the Big Bend facilities, Units 1, 2, and
3, by 36 percent and potentially effect a proportional reductio^i
in the level of entrainment measured* The Regional Administrato
viewed the company's proposal as a viable means to establish a
new basis from which to reassess the impact of entrainment at
this facility.
With the shut-down of the dilution assist cooling
system, the company demonstrated, through results of biological
studies, that the associated thermal rise of the discharge did
not cause substantial ard unacceptable thermal impacts in |
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Hillsborough Ba/ and Tampa Bay. Based on these findings, the
Regional Administrator further determined that the retirement
of the dilution assist cooling system provided for a significar
reduction in entrainment by minimizing the cooling water
capacity required by the Big Bend facility.
Therefore, the Regional Administrator determined
that the operation of Units 1 through 3 with the conventional
once-through cooling mode, without the benefit of dilution,
dilution assist cooling, resulted in a maximum level of
entrainment acceptable for the Big Bend facility.
Based on these findings, the operation of a fourth
unit at the Big Bend site would require installation of an
intake system designed to limit entrainment impacts to levels
currently associated with the operation of Units 1 through 3
and without the use of dilution cooling.
In response to the above, which established the
maximum entrainment impacts acceptable for the Big Bend site,
the company, Tampa Electric, assessed the applicability of
various intake technologies that would minimze entrainment
impacts on the biota of Hillsborough and Tampa Bay.
From these efforts, the company determined that a
relatively new technology, known as fine-mesh screening, had
potential application at the Big Bend site. Accordingly, the
company proceeded with preliminary experiments which led to
;
the construction of a full-scale prototype traveling intake j
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screen wtich included all features of an in-service installa-
tion.
The effectiveness of this design to successfully
screen fish eggs, fish* and shellfish larvae from the intake
water and return to organisms -- return the organisms to Hills-
borough Bay was deemed a viable state and was tested further.
In May of 1981, the final results of the company's
testing of the fine-mesh screening device was provided to EPA
for evaluation.
Based on the facts presented by the company, the
Regional Administrator determined that the fine-mesh screening
of intake structures is a viable technology that would minimize
entrainment effects. Therefore, the installation of fine-mesh
screens on Big Bend Unit 3 and 4 would provide for entrainment
effects approximately equal to the current impacts associated
with the operation of Units 1, 2, and 3, with conventional
intake technology.
The detailed results of the findings referred to
above, of course, will be found in the EIS when published.
Now, with the construction of Unit 4 and to ensure
that the installation and the operation of the in-service fine-
mesh screens attain the goals of entrainment minimization, the
efficiency of these installations on Units 3 and 4 will be
studied with results provided to EPA for evaluation.
Also, because the operation of Unit 4 will add to !
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tl.e heated discharge to Hillsborough Bay, biological studies
will be conducted at an appropriate time to assess any impact
due to these discharges.
Thank you.
MR. ZELLER:
Thank you, Mr. Hicks.
This generally concludes the statements by the
involved government agencies and EPA staff people involved.
We'll now proceed with the real purpose of this
evening hearing, and that's to receive public comments.
The goal of the Clean Water Act and the National
Environmental Policy Act is to encourage and provide for public
participation in the decision-making process for actions legi-
slated by these acts and to encourage government responsiveness
to public concerns and to promote a greater public awareness oi
the actions proposed by the Environmental Protection Agency.
We've asked all of you to register so that we may
have a record of those that are here in attendance and also so
that we can send you a notice of our determination regarding
the permit.
If you've not already registered and you wish to
make an oral statement tonight, please indicate your intent at
this time. I have a number of people who have already done so.
If there's anyone else who would like to make a statement, why,
please let me know. If you have a lengthy written statement,
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I'd like to ask that your oral presentation be summarized if at
all possible. Your oral presentation should be limited to
about seven to ten minutes or less if possible.
Now, Mr. Oven or I may ask questions of the persons
presenting oral comments where we feel like it's necessary to
clarify the nature or substance of those comments.
I'd like to emphasize that persons commenting for
the record will not be expected nor required to respond to
questions from the public.
On the other hand, since the purpose of this hearing
is for public information, I want to make sure that everyone
here, if you have a question, that you make it available to
the Chair, and either I will try to respond to it or see that
someone can answer it, because I think it's extremely important
that you understand all of the aspects of this complicated
process that's underway.
Now, I want to ask each person making a statement
to please step up to that microphone, state his or her name
and the interest or organization that you represent.
The hearing is being recorded by a court reporter,
and a transcript will be included in the public record of the
final EIS. In addition to any oral or written comments sub-
mitted this evening, the period on the Draft EIS will remain
open until September 2nd, 1981.
The written record of the hearing and any other
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comments received will be held as a matter of public record in
the Regional Office of EPA in Atlanta.
Now, at this time, as the first speaker relative
to public comments, 1 would like for the Tampa Electric
Company representative Who is going to make a statement, to
please do so at this time.
MR. TURNER:
Thank you, Mr. Zeller.
My name is Heywood Turner, Senior Vice-President/
Production with Tampa Electric Company, and I reside in Tampa,
Florida.
Before I begin my prepared comments, if I may, I've"
got a couple of items that I'd like to present to the Chair for
the record. These consist of, first, Florida Public Service
Commission Order No. 9749 dated January 16, 1981, together
with the Florida Public Service Commission final report with
regard to the certification of Big Bend Unit No. 4.
So, if I may, Mr. Zeller -—
MR. ZELLER:
Yes.
MR. TURNER:
Secondly, we have to present as comments on EPA's
preliminary determination of Big Bend Unit No. 4 PSD application
I have three brief comments that I would like to read and then
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enter into the record if I may. !
I
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4R. ZELIER:
You may.
*R. TURNER:
The first comment is found in Section E-5 and reads
as follows: In the discussion of BACT for N0X and CO, the
sentence -- in quotation marks — An attachment to this pre-
liminary determination summary specifies combustion control
requirements to balance the trade-off between N0X and CO
emissions through the use of a flue gas, oxygen, or CO2
monitor -- closed quotes.
This portion should be deleted since the attachment
and requirements have been deleted from the preliminary determi
nation, as noted in the response to comment no. 3 oh page.E-23.
Secondly, E-14, condition no. 11, the applicant wilfL
demonstrate compliance with the NSPS requirements for percent
reduction of potential sulfur dioxide emissions by monitoring
coal characteristics, flue gas, sulfur dioxide content, and
through other procedures established in 40 CFR Subpart D(a)—
as discussed on page E-4 -- the BACT analysis assumes a 25
percent reduction in potential sulfur dioxide emissions --
sulfur dioxide underlined -- not, parenthetically, sulfur
underlined -- through coal washing and preparation.
This assumption was based on coal washing data
indicating 25 percent reduction is possible. However, should
the coal washing and preparation not always provide a 25 percent
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or greater reduction in potential S02 emissions, flexibility
has been designed into the control equipment to achieve an
overall reduction of potential SO2 emissions of 90 percent.
For these reasons, condition no. 11, we feel,
should be deleted. And lastly, page E-17, table 1, potential
emissions of SO2, should read 15,552 tons per hour to reflect
the 0.82 pounds SO2 per million BTU emission rate. That is
included in the preliminary findings, I believe, Mr. Zeller,
if 1 may submit these.
MR. ZELLER:
Thank you.
MR. TURNER:
I've prepared a brief statement that I would like
to present to- you at this time. As I said, my name is Heywood
Turner, and I reside in Tampa, Florida, and I'm Senior Vice
President of Production with Tampa Electric Company.
We welcome this opportunity to appear at this joint
hearing as the applicant for the various permits necessary for
continued operation of Tampa Electric Company's Big Bend
generating station and construction and operation of the pro-
posed addition of Big Bend Unit No. 4.
Since the new unit is the primary subject of the
Draft Environmental Impact Statement that has been issued by
Region IV of EPA, my comments will be directed to that unit.
j
Of course, the renewal of the NPDES permit for the j
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existing Big Bend station is also of significance to the
2 company, and I will briefly address that as well.
3 By way of background on Unit No. 4, the issues that
we're here to address tonight are actually a part of three
major areas of government authorizations which are required
under various statutes and regulations for a new power plant
facility.
Two of these authorizations have already been ob-
tained by Tampa Electric Company. The first approval received
was the determination that there is a need for Big Bend Unit No
4 in the State of Florida. That determination was made by the
Florida Public Service Commission on January 16, 1981. I'll be
discussing that in a little more detail later in my comments.
The second major authorization obtained by the
company is the.certification of the site of Big Bend Unit No. 4
by Florida's Governor and Cabinet under the Florida Electric
Power Plant Siting Act.. That certification was granted at a
public hearing held by the Governor and the Cabinet in
Tallahassee, Florida, on August 4, 1981.
Tampa Electric Company — to give you a little back-
ground about the company -- was originally chartered in October
of 1899 and was reincorporated in 1949 and became a wholly-ownec
subsidiary of TECO Energy, Incorporated, in April of this year,
1981.
The company is an investor-owned, tax-paying electrljc
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public utility serving Hillsborough and portions of Polk, Pasco
and Pinellas counties.
Within that service area we serve customers within
the municipal limits of the cities of Tampa, Plant City,
Temple Terrace, Winter Haven, Auburndale, Lake Alfred, Eagle
Lake, Mulberry, Dade City, San Antonio, and Oldsmar. We
currently have more than 318,000 customers. As I have noted,
we are regulated by the Florida Public Service Commission.
The present generating capacity of the company is
2,475 megawatts. Of that total, 1,615 megawatts is coal-fired
capability. The last addition to the system that was placed in
service was Big Bend Unit No. 3, which began commercial opera-
tion in 1976.
Tampa Electric Company has built, maintained, and
operated its electric system with the primary goal of providing
reliable service to its customers at the lowest possible price.
Our principal role is now and has been to respond
to electric power needs of our customers in a manner which will
provide efficient capacity to ensure reliable service.
It is our judgment that Big Bend Unit N6. 4 is re-
quired by the projected April 1985 in-service date to ensure a
reliable cost-effective supply of energy for Tampa Electric
Company's customers.
The Big Bend generating station, which is the subjecji
1
s j _ inrfltfid on¦ tlifi fiflstcm shors of '
of this public hearing, is located
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Hillsborough Bay approximately five miles north of Ruskin, ten
miles south of Tampa, and fourteen miles from St. Petersburg
across the bay.
4 The station currently consists of three coal-fired
5 generating units known as Big Bend Units 1, 2, and 3. The pro-
6 posed new unit will be the fourth unit at the existing site
7 and will utilize many of the service facilities that are
8 associated with the existing units.
9 The shared facilities include such things as the
10 coal dock, unloading facilities for coal, coal storage area, thje
existing wastewater treatment pond, and spray irrigation field.
12 The existing transmission line towers will be
13 utilized by Unit No. 4 so that there will be no need for new
14 transmission towers to accommodate this new unit,
is Big Bend Unit 4 is designed to have a gross genera-
16 ting capability of 486 megawatts. The number of 417 megawatts
17 was mentioned previously; that was the net capability of the
is machine. The number I cite here of 486 is the gross capability
19 of the machine.
20 In accordance with state and federal statutes and
21 regulations, this unit will be equipped with a flue gas desulfujr-
22 ization system or stack gas scrubber to control the emission of
23 sulfur dioxide to the atmosphere. It will also be equipped with
24 an electrostatic precipitator to control emissions of particulate
25 matter to the atmosphere.
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These systems consist, in our judgment, of what is
often referred to as a state-of-the-art technology and have
been thoroughly investigated by the company to ensure that
both reliable and economic operation will be possible.
We are convinced, based upon our evaluations, that
these systems constitute the best technology that's currently
available in the market for the removal of these parameters.
Fori the entire Big Bend station, including proposed
Big Bend Unit No. 4, a concern has been expressed by state and
federal agencies and other groups about the impact of the
station on the bay. Mr. Hicks was referring to this moments ag
Tampa Electric Company has utilized a once-through
condenser cooling system for the existing station, and the same
type of system is proposed for Big Bend Unit No. 4.
To address these concerns, extensive studies were
performed in Hillsborough and Tampa bays. These studies in-
cluded assessments of the impact of the heated discharge water
on living organisms in the bay as well as assessments of the
impact on those organisms of drawing the water into the plant.
Based upon our evaluations and in consultation with
both the Department of Environmental Regulation and EPA, it
was determined that impacts that may occur as a result of the j
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use of once-through cooling for this station could be sub-
stantially mitigated if a fine-mesh screen system is incorporatf
into the plant cooling water intake structure.
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The prototype or model of the fine-mesh screen
system was constructed and operated to determine the effective-
ness of this new technology for the Big Bend station.
Based upon these studies, EPA has tentatively
determined that the installation of fine-mesh screens on pro-
posed Unit No. 4 and on existing Unit No. 3 will be sufficient
to ensure that the potential impacts are at an acceptable level
and once-through cooling may be utilized at the site.
Other environmental safeguards will be employed at
the site to ensure that non-reusable byproducts that are pro-
duced as a result of the generation of electricity in a coal-
fired facility are disposed of in a responsible and safe manner.
These are all addressed in the Draft EIS.
As I pointed out earlier, since the proposed Unit
No. 4 is a new unit, the Florida Public Service Commission was
required to assess the need for the additional generating
capacity.
To demonstrate the need for Big Bend Unit No. 4,
the company conducted studies on projected customer growth,
energy demands, conservation, alternate energy sources, and
available system capacity and reserves.
After evaluating the relevant data, the Florida
Public Service Commission certified the need for the unit. We
firmly believe that the Public Service Commission decision is
correct and the addition of Big Bend Unit No. 4 to Tampa
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Electric Company's generating system will ensure that the
energy demands forecasted for the in-service date of April 1985
and beyond that date can be met in a reliable, responsible,
and cost-effective way.
One further point that should be — should not be
overlooked is that the addition of coal-fired generating
capacity is consistent with both the Public Service Commission
rules and the national energy policy of reducing reliance on
foreign oil. Big Bend Unit No. 4 will displace oil generation
in the State of Florida.
In summary, Tampa Electric Company and the respaisib
state and federal agencies have thoroughly studied and evaluate
the environmental, economic, and other consequences of construe
ting and operating Big Bend Unit No. 4.
We believe that these evaluations clearly demonstra|t
that the necessary permits and authorizations should be granted
as expeditiously as practicable.
We support the issuance of the National Pollutant
Discharge Elimination System permit, the Prevention of Signifi-
cant Deterioration permit, and the finalization of the Environ-
mental Impact Statement for this unit.
We also strongly support the issuance of the renewaL
National Pollution(sic) Discharge Elimination System permit for
Big Bend Units 1, 2, and 3, which has been proposed by EPA,
and we urge that the Department of Environmental Regulation
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certify that permit as required by the Clean Water Act of 1977.
I've been reading; this is obvious to you. Now I'd
like to talk, if I might, for just a minute.
This permitting process has been a long pull for
lots of people. Without the diligence, help, and assistance of
folks in Region IV, folks in the State of Florida, DER, these
gentlemen and your staffs, we'd probably not be here tonight.
I'd like to thank each and every one of you per-
sonally for the cooperation. We had some differences, too, but
it went well. I think we've come to a point where we can go
back and say a lot of work has been effectively done, and if
you'll allow me, I'd like to also make that same thanks to
many folks in Tampa Electric Company who have worked diligently
toward the end of arriving at the August permit for Big Bend
Unit 4.
Thank you, Mr. Zeller.
MR. ZELLER:
Thank you, Mr. Turner.
Next I'd like to move on with those individuals who
have indicated they would like to make a statement. The first
card that I have, based on the time of registration, is from
Ms. Gloria Rains. Ms. Rains is Chairman of Manasota-88.
Ms. Rains, nice to see you again.
MS. RAINS:
Thank you. I,am Gloria C. Rains of 5314 Bay State
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Palmetto, here to represent Manasota-88, a bi-county organiza-
tion dedicated to the preservation of environmental health.
Basically, after reviewing the TECO Draft EIS,
members of Manasota-88 conclude the following: It is by no
means certain that Big Bend Unit 4 is needed.
Based on investigation by the Public Service Com-
mission, it has been determined that the Florida peninsular
kilowatt hour capacity is sufficient without Big Bend 4, in
light of the anticipated attainment of Commission conservation
goals.
Even in TECO's more limited service area, TECO's
reserve margin will still be 11.7 percent for the winter of
1988-89. The recommended reserve margin of 23 percent or so
could probably be readily attained if TECO actively pursued
long-term power purchases outside Florida, which they admit
they have not done in depth.
While such a step may not provide the economic
infusion to TECO they desire, our concern is not with providing
a broader margin of profit for TECO but with providing a safe,
productive environment for Tampa Bay residents.
There is little doubt TECO's reserve margin could
be even larger. Rather than continuing to provide preferential)
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power rates to industry, primarily the phosphate industry,
whose present consumption is currently about 23 percent higher
than residential consumption, industrial conservation could be
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encouraged by charging industrial users the true cost of
electricity. This is important since industrial demand at
preferential rates will continue to exceed, although at a lower
percentage, domestic consumption through year 2000.
If TECO showed the same interest in conservation
that they parrot to their residential consumers, they would hav
a rate schedule that urges conservation which would eliminate
need for a new unit, if indeed one exists.
In any case, the residents of peninsular Florida,
if Public Service Commission goals are achieved, as seems most
probable, do not need the addition of Big Bend Unit 4.
Elimination of the proposed expansion will still
result in reserve margins of 33.7 percent in the winter of
1988-89, well over the recommended reserve margin.
Achievement of the PSC conservation goals will re-
move any need for Big Bend Unit 4 from an adequacy view. It
should also be noted that even without attainment of conserva-
tion goals, an unlikely event, it is possible an adequate re-
serve margin could still exist.
We believe existing facts substantiate that the
construction of the proposed unit is not the most efficient |
way for TECO to provide adequate power to its service area |
customers.
As far as the so-called socioeconomic benefits of
Big Bend 4, we believe those listed in the Draft are more than
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offset over the long term by the adrfi
y n addition of toxic met. Is into
our surface waters, degradation of ^ groundwacer from ^
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Sulfur dioxide levels will be increased by between
12,000 to 24,000 tons per year, certainly not helping the sulfur
dioxide problem in Pinellas, Hillsborough, and other adjoining
counties.
While, because of the application's timing, in-
creases in particulate matter emissions from fugitive sources
have not been considered, they will most certainly have a
detrimental impact on air quality. At a minimum, these levels
will increase by 1,020 tons per year.
Permitted emissions of particulate matter will
result in increased particulate emissions of 568-plus tons per
year. Permitting this unit will make a bad air quality region
even worse, increasing morbidity and mortality levels and furth|e
adversely impacting the quality of life of area residents.
Surface and groundwater quality, already exceeding
state water quality standards in some areas, will be permitted
to become even further contaminated.
Major groundwater contamination sources from this
site will include the coal storage area, the sludge ponds, and
the landfill site. Poor quality surface runoff and leachates
generated in addition to the existing three units at these
locations will seep into the underlying aquifer. Movement of
leachate will be toward the Tampa Bay system due to natural
groundwater flow. Yet, there is no recommendation for the
bottom ash and gypsum disposal areas to be lined.
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A minimum 357,380 tons of sol:.d waste will be
generated each year consisting of bottom ash, economizer ash,
fly ash and gypsum. Although it is stated some may be disposed
of commercially, it is well known that this type of gypsum and
fly ash are not really suitable for use in wall board, crops,
etcetera. |
Most probably, all of the toxic and radioactive
material will be dumped into on-site landfills and waste ponds
where it will leach into the groundwater. This seepage will
introduce radionuclides and other potentially harmful elements
into the growth medium of local vegetation. It will further
degrade the water quality of the surficial aquifer, which, at
the Big Bend site, already exceeds EPA standards for chloride,
sulfate, manganese and total dissolved solids and exceeds the
suggested standards for arsenic.
The permit says there shall be no discharge from thij
runoff from the gypsum storage or disposal areas. Yet, the E1S
says low volume wastes and metal cleaning wastes are discharged
to waste ponds for evaporation and percolation where they will
seep downgradient into surface waters.
Total suspended solids present in the plant water
will be passing through the slag ponds in concentrations which
exceed effluent limitations.
Further, permitting, as is proposed, the discharge
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of heavy metal pollutants when ambient levels of arsenic,
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cadmium, chromium, copper, iron, mercury, nickel and selenium
already exceed Florida Water Quality Standards will not only
violate the water quality standards; it would also appear to
clearly violate the intent of the Clean Water Act. Such dis-
charges will also cause serious additional degradation of area
waters and have the potential to adversely impact human health.
We can find no sound reason to provide the applicant
with a variance to violate standards for two years. The
applicant should absolutely be required to provide additional
treatment of their wastewater in order that there be no further
violation of water quality standards in the area.
How is the applicant, as it is stated in the Draft,
going to take all reasonable steps to minimize adverse impacts
to waters of the United States when you permit him to violate
water quality standards for heavy metal pollutants?
We know that the thermally-affected region associate
with the Big Bend facility has suffered decreases in animal
abundance and species diversity and a general decline in the
quality of the bentho macro-invertebrate community has occurred.
The addition of Unit 4 will increase the heat load
to Hillsborough Bay by approximately 33 percent, providing an
enlargement of benthic areas presently subject to adverse
effects, again making a bad situation worse.
The use of fine-mesh screening as an intake device I
to reduce mortality of fish eggs and invertebrate larvae would i
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result in a minimum mortality of 44 percent. Further, it .s
not even really established that this screening device will
enhance the survival of fish and larvae. It should also bt
noticed -- noted the entrainment impacts associated with Ui it 4
are approximately equal to the total impacts associated witi
operations of Units 1, 2, and 3.
It should also be noted that the unit will contri-
bute to the acid rain problem.
In summary, then, you're proposing to issue permits
which will require variances because certain standards are not
presently being met. This, in order for a px ; to be con-
structed that is probably not needed and is going to cost the
residents of this area dearly in increased utility bills,
adverse health impacts and environmental impacts.
We think this is in violation of at least the spiri
of the Clean Air Act and the Clean Water Act. It is certainly
not in the long-term national, state, or local interest to
destroy more of our commercial and sports fishing industry, aid
in the further destruction of our air and water quality which I
will further erode adjacent areas, tourist and retirement
economic base, increase health costs and through support of an
unneeded facility result in an economic negative when invest-
ment of money is needed elsewhere in our economy.
If the plant is permitted anyway, we would suggest,j
rather than waiting two years, the terms of the NPDES permit j
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should require that co.itrol systems, such as reverse osmosis
or chemical treatment, be used to reduce the levels of metals
in discharge of effluents containing toxic metals.
The gypsum pond and bottom ash disposal areas,
etcetera, should be lined, although this is far from a fool-
proof situation.
We should also add, as far as finding any security
from the so-called reopener clause found in Part III-D, once
the plant is permitted, these permits are not going to be
significantly changed; nor, based on our experience, will there
be any extensive, meaningful clean-up of operations.
Thank you very aiuch.
MR. ZEL1ER:
Thank you, Ms. Rains.
Next I'd like to ask for Sally Thompson, who vis
Chairperson of the Hillsborough Environmental Coalition.
Ms. Thompson?
(Pause)
MR. ZELLER!
Go ahead. That's a recording device; that's not a
speaker.
MS. THOMPSON:
Oh, okay. There's not a microphone, then?
MR. ZELLER:
No. Simply to get your statement on the record, so
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if you'll state your name.
MS. THOMPSON:
I'm Sally Thompson, and I'm Chairperson of the
Hillsborough Environmental Coalition, and I'd like to say, just
for starters, that Gloria Rains pretty well covered most of
our concerns.
On behalf of the Hillsborough Environmental
Coalition, which is comprised of concerned individuals and
organizations in the Tampa Bay area, such as the Audubon
Society, Sierra Club, Save Our Bays, Citizens Against River
Pollution, Gulfcoast Lung Association, and various other civic
associations, I'd like to go on record expressing our concern
with conservation measures and other alternatives that have not
been addressed adequately in this DEIS.
You will be receiving written comments from the
Coalition within the required time frame as well as comments
from experts within our organization.
It is our hope that alternatives to power plants
will be seriously considered in the future. Do we really need
more power plants? Perhaps it will be concluded that additiona
power plants are not the answer, especially when we live in a
county that has the dubious honor for having the worst air
quality in Florida. j
Because of our concerns for the quality of life in j
Hillsborough County, which is a microcosm of all the environment
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problems and concerns in the state, such as growth, land use,
air and water quality, energy, solid waste, etcetera, we must
seriously pursue the avenues of conservation and other alterna-
tives . j
With a year-round temperate climate, Hillsborough
County could be a showplace. It seems a shame that EPA did not
see fit to consider conservation as an appropriate management
alternative for Big Bend 4.
We hope in the future that conservation and other
alternatives to power plants will be strongly pursued.
Thank you.
MR. ZELIER:
Thank you, Ms. Thompson.
Next I'd like to ask for Mr. Richard T. Panel. Hav<>
I pronounced that right?
MR. PAUL:
Paul.
MR. ZELLER:
Paul; I'm sorry. Mr. Richard Paul from the Hills-
borough Environmental Coalition.
MR. PAUL:
Thank you, Mr. Zeller.
I'm speaking tonight as the Water Quality Chair for
the Hillsborough Environmental Coalition.
I'd like to mention a few specific problems rather
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than paint with a broad brush and «
' and the first of these is acid
rain, which I believe the Draft
Environmental Impact Statement
waves at but does not appropriately hi
vv upnaceiy discuss. It's a problem
emerging in the United States that-'* „ u
s perhaps of some magnitude,
find I think it should be treated
creacea that way in Florida as well.
We believe that much closer attentlon shoul
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The whole question of the biological impact of
thermal effluent being carried into the embayment by rising
tides has apparently been ignored. It's our tinderstanding that
as part of the permitting process for the previous units at Big
Bend, an agreement was reached that if the present sheet pile
wall was determined to be too short to prevent thermal effluent
from entering the embayment, causing damage, it would be modi-
fied or extended. We would appreciate a clarification on that
point.
We believe the problem of thermal loading in the
embayment requires further study, and if it is shown to be a
problem, modifications of the discharge canal and/or sheet pile
wall should be required.
It's our -- excuse me -- it's our understanding
also that ash and scrubber sludge storage areas present potentij
long-term toxicity problems from heavy-metals contamination.
TECO should give assurances of their permanent commitment to
maintain these sites in a manner that is safe, both environ-
mentally and for public health.
And lastly, we believe that as mitigation for other
environmental effects, many of which have been mentioned already
fine-mesh screening should be considered on Units 1 and 2 as
well. It may not be possible to require this of TECO, but I
would hope that TECO, as a publie-spirited organization, would
consider the possibility.
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Thank you.
MR. ZELLER:
Thank you, Mr. Paul.
Let me suggest We will, of course, respond to
your comments formally. That's why we're here, and that's
why we're putting them on record, but I think. Mr. Hicks
covered, Delbert Hicks, covered some of the aspects that you
were talking about, and I'd like to suggest that you find an
opportunity to meet with him after the hearing for a little
further clarification. Thank you very much.
MR. PAUL:
Thank you very much.
MR. ZELI£R:
Next I d like to ask for Mr. Michael Kenney from
the Hillsborough County Environmental Coalition. Mr. Kenney?
MR. KENNEY:
The Hillsborough Environmental Coalition is con-
cerned about the air quality impact of the proposed project,
because the Big Bend site is within close proximity to two non-j
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attainment areas of the National and Florida Ambient Air Quality
Standards; that is, the portion of Hillsborough County designa-
ted as a non-attainment area for suspended particulates and a
portion of Pinellas County that is designated as a non-attainmeij]
for sulfur oxides.
A careful review of the Draft Environmental Impact
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Statement of Big Bend Unit No. 4 indicates to us a need for a
clarification of the following points with regard to air
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quality:
Item 1: The modeling for S02 shows that the
resultant estimated three-hour concentrations will consume
84 percent of the National Ambient Air Quality Standards.
The modeling also shows that the impact on Pinellas
County SO2 non-attainment area will be 80 percent of the
allowed applicable emission offsets for this facility.
These computer modeling estimates are based on the
assumption that coal, the sulfur content, of three to six
pounds per million BTU's will always be available.
The Hillsborough Environmental Coalition is con-
cerned that these SO2 projections are very close to insulting
the air quality standards and that they are formulated on awea
non-realistic assumption, and that is that coal, sulfur coal,
will always be available.
The Hillsborough Environmental Coalition feels that
Tampa Electric Company must employ some SO2 control technology
to ensure that the air quality is kept at the prescribed health
protection standards.
With regard to particulate matter, total emission
inventory for the new unit and associated facilities seems, in
a word, excessive. The combined calculated particulate matter
emission volumes are as follows, in terms of tons per year,
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and I'm taking this out of the EIS report:
In the coal-handling facilities, uncontrolled
emissions are estimated to be 900 tons per year. From controlle
coal-handling facilities, estimates are 120 tons per year.
From the boiler, an estimation of 568 tons per year was calcu-
lated. The sum of these three figures is 1,588 tons of par-
ticulates emitted per year from this facility.
This value of 1,588 tons of particulate matter
released annually is not compatible with the Hillsborough
County goals of cleaning up a non-attainment area that lies
within a few meters of the site.
I'd also like to refer to a table in the 1979
edition of environmental quality of the Hillsborough County
Environmental Protection Commission. Table 2.2-1, entitled
Emission Inventory 1979, stationary sources of air pollution,
and their estimates for the current TECO Big Bend site -- that
is the three units --is 1,236.
In a nutshell, the projections for this new unit ar»
exceeding the emissions projected emanating from the first threu
units that are already in operation.
The modeling for particulate matter, as shown in
Table 3-12 in the EIS report, indicate that the Big Bend unit,
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Units 1 through 4, with all interacting sources, will come
within 85 percent of exceeding the twenty-four-hour TSP stan- ;
dards.
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We feel that modeling for particulate matter of the
entire facility should be redone or recalculated showing the
combined effects of the boiler, the coal-handling facilities,
the fugitive dust generated from additional vehicles used at
the facility.
In conclusion, if attempts are not made to remedy
these proposed problems as identified above and the preservation
of air quality in the Tampa Bay air shed is not pursued by the
utility, the Hillsborough Environmental Coalition will solicit
public support to ensure that these problems are properly
addressed and corrected.
Thank you.
MR. ZELIER:
Thank, you, Mr. Kenney. I appreciate your comments .
The next speaker is Laurie Macdonald Rask with' the
Tampa Bay Sierra Club.
Ms. Rask?
MS. RASK:
I'm Laurie Macdonald Rask, Chair of the Tampa Bay
Sierra Club. |
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Tampa Bay Sierra Club is concerned over the lack of j
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action and interest by utilities and governmental agencies in <
pursuing alternative energy sources.
Innovative, effective long-term programs, which are
based on conservation, direct fuel use, cogeneration, and sola^
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and other renewable energy sources are economically ani environ-
mentally productive. Such alternatives have been given little
attention in the Big Bend 4 Environmental Impact Statement, anc
we fear that little attention will be given to these alternative
in our region's future.
Serious consideration of the alternatives would
eliminate thfi need, if any, for Big Bend 4. As you're well
aware, the general public is not technically knowledgeable with
regard to power plant operations. Citizens expect the Environ-
mental Protection Agency to pursue effective long-term solutionis
to energy needs which protect our environment.
At the same time, citizens desire financial stabilil
ty. A positive environmental and economic solution can co-
exist. There are real and viable alternatives to the present
attitude of building expensive, environmentally-damaging
coal-fired power plants.
We will be looking to TECO and our governmental
agencies to seek these alternatives in the future.
Thank you.
MR. ZELLER:
Thank you very much.
The next speaker will be Julie Morris who's Vice
Chairman of the Florida Sierra Club.
Ms. Morris?
MS. MORRIS:
My name is Julie Morris. I'm Vice Chairman of the
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Florida Chapter of the Sierra Club. I reside i:\ Sarasota,
Florida.
I'd like to start out by commending TECO for its
plans to utilize both scrubbers and electrostatic precipitators
to abate some of the air emissions that will be potential from
the plant. I think TECO should also be commended for its
planned use of fine-mesh screens to reduce the mortality of
eggs and larvae of estuarine organisms in its cooling water.
I'd like to state that we support EPA's assessment
that from a purely environmental viewpoint, Big Bend No. 4
should not be constructed, and we find very valuable the in-
formation provided by EPA about the heat loading and the benthi<
impacts of the Big Bend No. 4 plant.
We would like to criticize EPA for taking what we
see as an inadequate look at the conservation, alternative in
their Environmental Impact Statement on Big Bend No. 4.
Every time the conservation alternative or the
question of need arises in this EIS, EPA has deferred to the
determination made by the Florida Public Service Commission.
That determination states that when you look at the
whole peninsula, there's no need for Big Bend No. 4, but when
you look it just the TECO service area, need for another unit
is evident.
Economic growth in the service area is identifiad
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as a decisive factor in this determination of need in the local
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area. We would encourage EPA to k j .
» rA Co 1o°k beycnd the PSC determina-
tion of need and also to look Kawn„j ^
OOK bey°nd the conservation goals of
the Public Service Commission.
We believe that a erpat- jaai
great deal more can be achieved
on the conservation front.
Taking a look at the TECO i
service area, we know
that industrial users consume 23 percent more than residential
users in the service area. This margin is declining, and by
1989 industrial users will only outstrip residential users by
10 percent.
We're curious about what percent of the industrial
use is used by the phosphate industry, we view industrial use
of electricity by phosphate mining as imminently interruptable
during peak load periods, and in fact we view slowing down
strip mining for the purpose of lightening peak loads as being
good for the biological resources and water resources of the
region.
We also believe that phosphate mining in the region|
will probably be more short-lived than Big Bend No. 4 if curren
rates of phosphate extraction continue.
Increased residential demands during the 1980's in
the service area are expected, and the EIS details that Tampa
Palms plans 13,497 units, and two U.S. Homes developments will
total 8,500 units. These are both mentioned in Appendix G.
If winter peak loads are the primary reason for
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needing new capacity in the servict area, why not make sure tha
the houses in these large new developments use non-electric
heating systems. Electric baseboard heat is inefficient, and
surely the cost of building Big Bend No. 4 is far greater than
the cost of ensuring that all these new homes don't rely on
electric heat.
We're convinced that conservation beyond the goal
set by the Public Service Commission is achievable in the TECO
service area and that investments in conservation are a better
deal for TECO and for the air and water in the Tampa Bay region
than investments in an additional unit at Big Bend.
Another issue, we find confusing the various
estimates of reserve capacity during the winter peak of 1985-86
contained in the EIS. Without Big Bend No. 4, we find reserve
capacity estimated at 21.3 percent on page 6-3f at 13 percent
on page G-2, and at 9 percent on page 1-4. We'd like some
clarification on what the actual:reserve capacity is supposed
to be in that winter season.
Finally, the attractiveness of adding a coal unit
to the Florida Power generation system to displace oil genera-
tion appears to have been considered heavily as a balancing
factor to the local environmental impacts of Big Bend No. 4.
We find that this argument has been used consistent
when the environmental impacts are mentioned in the summary
sections of the report as a balancing factor.
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It is our opinio,\ that conservation is a better
alternative than building Big Bend Unit 4 at this time.
Thank you.
MR. ZELI£R:
Thank you, Ms. Morris.
Next I d like to ask Mr. Barney Capehart, Chairman
of the Power Plant Siting Group with the Sierra Club.
Mr. Capehart?
MR. CAPEHART:
(Presenting)
MR * ZEXJLER:
Thank you.
MR. CAPEHART:
Mr. Zeller, Mr. Oven. My name is Barney Capehart.
I represent the Florida Chapter of the Sierra Club in my po-
sition as Chairman of the Power Plant Siting Committee.
The Florida Chapter of the Sierra Club is greatly
concerned about the economic and environmental effects of
Florida's move to build coal-fired power plants.
Several recent studies, some of those done by the
federal government, some of those done by Florida institutions
and universities, have identified a series of problems associa-
ted with coal-fired power plants in general and in our state in
particular.
Some of these problems have already been addressed t
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problems of air pollution, water pollution, coal ash disposal,
scrubber sludge disposal, radioactivity, visibility reduction,
acid rain, coal transportation hazards.
One of our concerns now rests with the current
attempts to modify the Clean Air Act. Presently, power plants
are required to meet the Best Available Control Technology.
Under proposed amendments to the Clean Air Act,
this would no longer be a necessary condition, and it's possibl
that the Tampa area, which already enjoys some of the worst
air in the State of Florida, could be facing the operation of
a coal-fired power plant without scrubbers under these re-
visions to the Clean Air Act.
That's a significant change in air standards and
would have a significant effect on the people of Tampa.
The major concern of the Sierra Club is that we
recognize the need for energy services, we recognize the need
to reduce dependence on oil; but building coal-fired power
plants is not the only solution to these problems, and it
certainly isn't the best solution to these problems.
Other alternatives are available which are undeniab*
cheaper, don't have the environmental degradations, and displacc
as much oil as if coal-fired power plants were used.
The State of Florida relies heavily on its image of
clean air and clean water to attract tourists, new residents
and industry. !
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We can't afford to fn.,i «
1 °ur own environment with
a poorly-justified policy to burn „
greater amounts of coal.
Some of the alternatives that are available to
burning coal involve use of coal-oil mixtures, increased
supplies of natural gas, direct use of ml a ^
oil and gas, conserva-
tion through approved energy efficiency of end use, use of
cogeneration, use of solar and renewable energy sources.
The Florida Chapter of the Sierra club has express4
its concern on numerous occasions to the EPA. We have specific
ally requested in the past that EPA ,
r unat tra consider alternatives to
this coal-fired power plant.
In particular, we requested that conservation and
renewable sources be one of the alternative studies in the EIS,
that the conservation/renewable alternative receive considera-
tion and equal study to any other alternative, and that the
EPA use a model, known as the EDF or Environmental Defense Fund
Wllley model, previously endorsed by EPA in other power plant
sitings, to investigate the alternative and impact of these
policies.
The Draft Environmental Impact Statement does not
address these concerns. Conservation alternatives are dismissed
in a very small paragraph. The Draft EIS discussion of conserv?
tion relies basically on the conclusion of the Florida Public
Service Commission that conservation was not a viable alternatil<
!
to Big Bend 4. This conclusion is erroneous. The Florida Publi<
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t
Service Commission never conducted any investigation to answer
the question as to whether conservation or some other alternatiju
could replace Big Bend 4.
The analysis that was conducted by the Florida PublL
Service Commission looked at the goals under the Florida Electri
cal Energy Conservation Act, known as FECA, and concluded that
if the goals of FECA were met, then this plant was not needed
on a state-wide basis and was only marginally needed in the
TECO service area.
But the FECA goals do not represent by any means
the magnitude of the potential for conservation and alternative
programs. The FECA goals represent a cosmetic approach; that
is commendable, because it puts the State-of Florida in a
posture of adopting conservation, but the magnitude of those
goals is so far below the potential available that it does not
represent a logical conclusion that conservation was investigated
is an alternative to building this coal-fired power plant.
Conservation plans submitted by TECO, as well as
ither utilities in the state, have shown large numbers of cost-
effective programs involving conservation, cogeneration,
enewable energy sources that are presently available, cost-
ffective, less-environmentally damaging, and could be pursued
a replacement of the need for a coal-fired power plant.
I think there's significant expectation that the EPA
Lved up to its responsibility under the law to see that this
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stidy of alternatives was performed, that the results would be
the same for the Big Bend 4 plant as it was for a project known
as the Allen-Warner Valley complex, presently perceived by the
State of California. This project was investigated using this
EDF Willey model. The results were that conservation, co-
generation, and alternative sources, renewables, provided a
cheaper, more cost-effective way to meet the energy needs
without building the large coal-fired complex in the Allen-
Warner Valley.
Since the TECO Big Bend 4 plant is small compared
to the overall capacity of the system, there's every reason to
believe that the output of that plant could be replaced by
these alternative sources.
The failure of EPA to pursue such a study in the
TECO case appears indicative of EPA'9 new role in favoring
industrial expansion requests regardless of the physical and
economic cost to the consumer.
Numerous conservation alternative programs are
possible. In an attachment to my prepared statement, I have
looked at one of the countless programs that could be put down j
|
on paper where the output of the TECO Big Bend 4 plant could bej
I
supplanted by any number of conservation, solar, renewable, J
cogeneration programs.
This one is strictly related to the residential
sector. It looks at a program involved with replacing
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refrigerators by high-efficiency models, replacing resistance
water heaters with gas water heaters, replacing strip electric
heaters with gas heaters, replacing central and window air
conditioners by high-efficiency models available on the market,
This particular plan for the 300,000 TECO residen-
tial customers would result in eliminating the need for the
entire output of the Big Bend 4 plant.
This, then, is proof that there is a conservation
alternative to the Big Bend 4 plant. Such an alternative was
not studied. It does-not appear in the EIS, and because of
that, the Sierra Club declares the Environmental Impact State-
ment to be inadequate under the law, and that in order to compl
with the provisions of NEPA that such an analysis of these kind
of alternatives must be performed before this plant can be
approved.
Part of these conservation alternatives involve
changing customers' consumptions arid things :that they use, and
although utilities frequently allege that they have no control
over customers' efficiency decisions, the truth is that innova-
tive programs can indeed influence appliance marketing strate-
gies, as witnessed when the utilities promoted electric ap-
pliances in all-electric homes.
Furthermore, the policy of having private industry
promote social policies, rather than the government, appears
i
to be the cornerstone of President Reagan's philosophy. Thus,
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if EPA studies Chess sltcnidtivpQ anj _
Clves a*id Proves that conservation
is a more cost-effective alternant
alternative, then TECO would have the
opportunity to embrace President Reaoan'o «
Keagan s economic philosophy
wholeheartedly.
The very purpose of having a requirement for an
evaluation of alternatives for new coal-flred power plants ln
the EIS is to aid in identifying options that are cleaner,
cheaper, and better for the citizens involved.
The EPA has not only failed in its legal obliga-
tion to provide a thorough analysis of alternatives, but it's
also failed the vast majority of Florida citizens »ho want
clean air, clean water, and the least expensive approach to
satisfying our energy service needs, not our electric needs,
but our energy service needs.
The EIS concludes with a statement on these alterna
tives that the Commission -- meaning the Florida Public Service
Commission — concluded that if its conservation goals are
achieved, Big Bend 4 may not be needed from the standpoint of
the peninsular system's capacity.
However, the Commission also concluded that it
appears that the proposed unit is needed for TECO's system,
whether or not raCO achieves the conservation goals allocated
i
to it. j
Accordingly, conservation was not considered to be
an appropriate management alternative. This conclusion
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represents an abrogation of the responsibility of the EPA to se
that a thorough analysis of alternatives was conducted. Ag^in,
the PSC analysis looked at the Florida Energy Efficiency Con-
servation Act goals, made a conclusion with respect to those.
It did not, absolutely did not analyze conservation
and alternatives under the condition that they might totally
replace the TECO Big Bend 4 plant.
The Draft EIS is clearly inadequate, and a thorough
study of these alternatives must be performed in order for EPA
to meet its legal obligation required under NEPA.
NEPA is very clear in saying what is required. The
CEQ guidelines, which are to have been the implementing regula-
tions for what is to be done under NEPA, state very clearly
that alternatives are to be included and represent the very
heart of an Environmental Impact Statement. It says that
agency shall rigorously explore and objectively evaluate all
reasonable alternatives, shall include reasonable alternatives
not within the jurisdiction of the NEPA agency.
The CEQ regulations emphasize the identification
and analysis of real alternatives and stress that the environ-
mental impact analysis is to concentrate on alternatives, the
heart of the process.
In particular, the CEQ comments on regulations
emphasized that the examination of alternatives is a requiremen
I
that is firmly established in the case law interpreting NEPA. |
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In addition, another section of the CEQ regulations
specify particularly that with regard to energy facilities
that energy requirements and conservation potential of various
alternatives and mitigation measures must be examined.
These requirements are clear, that EPA has a legal
responsibility to identify and study all viable alternatives.
The Calvert Cliffs decision, a legal case involving
the Atomic Energy Commission, was a case that made clear that
alternatives had to be evaluated under the NEPA law.
EPA has also established a precedent in the case of
the Allen-Warner Valley complex in California where a study
performed by the Environmental Defense Fund was wholeheartedly
endorsed by EPA, and the result was that that complex was
denied the necessary permits, therefore resulting in the can-
cellation of that project, again because alternatives were
shown to be cleaner, cheaper, and preferable.
Here in our own state we also have a good show by
EPA; in the case of the Jacksonville Electric Authority plants
currently being proposed, EPA is conducting an independent
investigation of alternatives. This investigation is not being
performed for the TECO plant. The reason for that I do not
understand. It is clearly required under the law, and as far
as the Sierra Club is concerned, we believe that the Environ-
mental Impact Statement is inadequate until this has been
corrected.
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JEA, unlike TECO, is a 100 percent oil-fired
utility. It, therefore, has even more reason to consider the
need for coal-fired capacity. TECO has substantial coal, and
there's little reason to feel that additional coal-fired
capacity is needed.
The Sierra Club reiterates its formal request that
EPA adhere to the requirements of the law in: formulating the
final Environmental Impact Statement for the TECO Big Bend 4
plant.
Following minimum legal requirements should be
standard EPA agency procedure and should not require legal
battles from citizen groups to ensure compliance with the law.
Thank you.
MR. ZELIER:
Your comments are duly noted. May I ask if --- I
have heard several other speakers address this need for power
and conservation issue, and EPA, I think -- whether erroneously
or not -- normally assumes that these are types of issues that
are brought before state public service commissions, and this
body is generally recognized as the body that has the responsi-
bility.
I would just --- I'm inquiring here. I presume you
have made these same comments to the Public Service Commission
in the hearings that were held and — the site certification
I
hearings with the State, or have you? I guess that would be --|
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MR. CAPEHART:
No, I did not —
MR. ZELLER:
f
--my question.
MR. CAPEHART:
-- make those same comments in that particular
forum. I have made those comments to the State Public Service
Commission in general before. It is the policy of our Public
Service Commission not to investigate alternatives in detail.
That's unfortunate. That's also an abrogation of their duty,
but nonetheless such a study has never been performed. There
is no such study available that anyone can point to.
Various conservation measures were looked at to
some extent, but there was never a program to the extent that
I've described where conservation potential has been investi-
gated.
There is no doubt that the utilities, including
TECO, have a responsibility now, under our FECA Act, to pursue
energy conservation programs, and some of these things that I j
mentioned are being done, but they're being done on a very smali
i
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scale, and they do not represent by any means the totality of ti
potential.
That's only for the residential sector also that ;
I've worked out there, which represents 35 percent of TECO's
load. If you can completely eliminate the need for that power
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plant by only looking at a program that addresses .15 percent
the load, what can you do when you look at cogeneration and
look at commercial reductions due to the same energy-efficiency,
programs, so there's no question that there's a tremendous
potential for conservation there.
The idea of investigating the cost-effectiveness
these alternatives is impossible, because the alternatives are
not identified. They're not even specified. So you can't
follow through on a requirement that these be evaluated. I
can't look at the EIS, nor can any other interested person lool^
into it, and try to understand the cost-effectiveness evaluati^
because there isn't one. There is no program identified that
would lead them to a subsequent cost-effectiveness analysis.
So the fact that the Public Service Commission did
not do this, I don't believe relieves EPA by any means; nor do
I believe that the case law supports that, and I believe EPA
is bound under the law to make sure that this is done.
If the PSC didn't do it, then somebody has to do i^
and EPA has the whole force, the complete force, of the law
behind it in requiring that analysis to be performed and be
included in the EIS before the approval process is granted.
MR. ZELLER:
Well, clearly, EPA will respond to the extent that
we're required to respond under the statutes that we operate
under. We have no problem with that, and, of course, as you
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pointed out, NEPA does require an assessment of alternatives.
To the extent that should be carried out, I cannot make a judg-
ment at this time. You've asked for a very comprehensive
evaluation of alternatives which may or may not be appropriate,j
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but I appreciate your comments. They've very They've very
well-done, and they're very thought-provoking.
Do you have anything, Mr. Oven?
MR. OVEN:
No.
MR. CAPEHART:
Thank you, Mr. Zeller.
MR. ZELLER:
Is there anyone else who would like to make
That's all the cards that I have. Is there anyone else in the
audience who has registered and indicated they wish to make a
statement who would like to do so at this time?
(No response)
If not, we'll proceed to formally close out the
hearing. One more time; is there anyone who would like to make I
a statement?
(No response)
Let me thank you who did make presentations tonight
and others who have attended this hearing. I appreciate your
cooperation and the thought and extent that went into your
statements.
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The record of the hearing and the comment period
]
will remain open through the close of business on September 2nd|,
1981. This will allow anyone wishing to submit additional
statements sufficient time to do so.
Further submissions to be included in the official
record must be in writing, and they should be sent to John E.
Hagan. That address is given at the bottom of the agenda that j
i
was handed out to you.
Although the customary procedure prohibits con-
struction prior to the final issuance of an NPDES permit for
new sources, EPA and the Tampa Electric Company had been ne-
gotiating an agreement, which is provided for in the regulation:)
whereby the company may commence construction at an earlier time
The company would have to agree to comply with all
ElS-related NPDES permit conditions, and only construction
activities of a reversible nature would be allowed.
Technically, this agreement has not been finalized
pending comments at this hearing which may affect the condition^
imposed by the EIS.
Now, after consideration of all the written comment!i
and of the requirements and policies of the Act and appropriate
regulations, the EPA Regional Administrator will make determina-
tions regarding permit issuance.
If the determinations are substantially unchanged,
the EPA Regional Administrator will so notify all persons
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making oral statements tonight and all persons submitting
written comments.
If the determinations are substantially changed,
the EPA Regional Administrator will issue a public notice
indicating the revised determination.
Now, within thirty days of receipt of the final
determination or the date of the public notice, any interested
party may request an evidentiary hearing on this determination
A request for an evidentiary hearing should be
addressed to the EPA Regional Hearing Clerk. The procedures
for filling out evidentiary hearing requests are set out in
Title 40, Code of Federal Regulations, Part 124, Subpart E, of
Volume 45 of the Federal Register on page 33498, which was
published on May 19, 1980.
Please note that any issues posed by an evidentiary
hearing request must have previously been raised by the request^
during the public comment period or at the public hearing.
Unless the request for an evidentiary hearing is
granted, our determination will be the final action of the EPA
Pending final agency action on an evidentiary hearing concerning
Unit 4, which is granted by the Regional Administrator, the
applicant will be without a permit as the project for which the
permit has been applied for is a new source.
For any hearings on Units 1 through 3, only the
contested provisions of the permit will be stayed.
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The record upon which the determination to issue is
made will include both comments received at this hearing and
received in response to the public notice.
The final permit will be issued no sooner than
thirty days after issuance of the final Environmental Impact
Statement, pursuant to 40 CFR 124.61.
We thank all of you again for attending here tonight
and participating in this public hearing.
If there's no further comments, I'll consider the
hearing now closed.
(Whereupon, at 9:12 p.m. the
hearing was closed)
BAY PARK REPORTING COMPANY
COURT REPORTING
33 FOURTH STREET NORTH
ST. PETERSBURG. FLORIDA 33701
(SI3) S23-S3SS
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CERTIFICATE
This is to certify that the attached proceedings before
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY and
THE FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION
Recreation Center
901 6th Street
Ruskin, Florida
7:30 "p.m.
August 19, 1981
were held as herein appears and that this is the
official transcript of the proceedings for the
file of the Agency.
BAY PARK REPORTING COMPANY
COURT REPORTING
33 FOURTH STREET NORTH
ST. PETERSBURG. FLORIDA JJ701
(813) 823-8388
Certified Verbatim Reporter
Official Reporter
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RESPONSES TO TRANSCRIPT COMMENTS
RESPONSE TECO-1
See response to written comment TECO-13.
RESPONSE TECO-2
See response to written comment TECO-14.
RESPONSE TECO-3
See response to written comment TECO-15.
RESPONSE GCR-1
See response to written comment SC-7.
RESPONSE GCR-2
Comment acknowledged.
RESPONSE GCR-3
Testimony presented during the Big Bend 4 Need Certification hearing before
the Florida Public Service Commission, addressed the adequacy of TECO's present
and projected generating capability. On Pages 5 and 6 of the testimony,
the winter of 1985/1986 is examined and Big Bend 4 is found to be necessary
to meet reasonable system reserve margins. The Florida Public Service Commission
has certified the need for Big Bend Unit 4.
The total projected TECO system capability in the winter of 1985/1986
without Big Bend Unit 4 is 2522 MW and the forecasted firm load (with
conservation) at that time is 2225 MW. This equates to a system reserve
margin of 13% and results in a high probability that the load could not
be served when planned maintenance and forced outages are taken into
account. The forecasted total load, including interruptible for the
winter of 1985/1986 is 2517 MW leaving essentially no reserve when firm
load and interruptible load are combined. While TECO bases its need
for additional generation on the analysis of firm load requirements,
it is reasonable to expect that interruptible customers will abandon
that class of service and move to a firm rate if interruptions become
excessive. Such a move would only exacerbate the problem and increase
the need for additional capacity.
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TECO performed an economic analysis of the impact of Big Bend 4 that shows
the unit will actually result in savings to the customer because of the
choice of coal fuel over oil. This is because a larger portion of the energy
generated for firm load will come from coal instead of oil. The following
tables presented at the Big Bend 4 Need Certification Hearing contain details
of this analysis.
RESPONSE GCR-4
The present yard grade elevation at Big Bend Station is 8.5 feet mean low
water datum. Accordingly, flooding at the site will occur only under ex-
treme storm conditions. To assure that material placed in the ash disposal
sites will not be affected by possible flooding, TECO has stated that they
will be designed and operated in accordance with Resource Conservation and
Recovery Act (RCRA) restrictions for construction of solid waste disposal
sites in flood plains (44 FR, 4356; September 13, 1979, "Criteria for Clas-
sification of Solid Waste Disposal Facilities and Practices").
RESPONSE GCR-5
The Hillsborough and Pinellas nonattainment areas will receive impact from
the proposed coal-fired unit. However, the dispersion of these pollutants
limits their predicted impacts to below the regulatory significance levels
(1 g/m^ annual, 5 g/m^ 24-hr, and 25 g/m^ 3-hr). Therefore, there exists
no basis whereby the Environmental Protection Agency can prohibit the unit's
construction or request a lowering of emissions. Increases in N0X ambient
concentrations are predicted to be 0.5 g/n? maximum, and are also less than
the significant level of 1 g/m^ on an annual basis.
The air quality dispersion analysis demonstrates that this unit's operation
will not affect air quality in these nonattainment areas with any degree
of severity.
RESPONSE GCR-6
EPA concurs in the technical propriety of the variance from metal criteria
for surface discharges. EPA believes there will be no significant impact
on ambient water quality in Tampa Bay as a result of the variance.
RESPONSE GCR-7
EPA recognizes that leachates may be generated from storage areas and ponds
associated with the Big Bend complex. For this reason the NPDES permit has
been conditioned to require implementation of a groundwater monitoring pro-
gram. If monitoring reports indicate contamination of the groundwater is
evident, corrective measures will be pursued to mitigate the contamination.
4-274
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TAMPA ELECTRIC COMPANY
GENERATION EXPANSION PLAN
Year
Capacity
Addition
Sal*
Without
Purchase
Purch.*
With
Purchase
Systea
Capability
(Annual Peak)
Total
Load
Fir*
Systea
Capability
(Annual Peak)
Total
Firm
Z
Load Reserve
Z
Reserve
Z
Load Reserve
Load
Z
Reserve
1980/81
2475
2152
15
1949
27
2475
2152
15
1949
27
1981/82
2477
2314
7
2036
22
150
2627
2314
14
2036
29
1982/83
2522
2372
6
2094
20
250
2772
2372
17
2094
32
1983/84
2522
2424
4
2134
18
250
2772
2424
19
2134
30
1984/85
2522
2470
2
2185
15
200
2722
2470
10
2185
25
1985/86
Big Bend
#4
208
2731
2517
9
2225
23
200
29j1
2517
16
2225
32
417 MW -
Coal
1986/87
104
2835
2568
10
2274
25
100
2935
2568
14
2274
29
1987/88
2939
2625
12
2331
26
100
3039
2625
16
2331
30
1988/89
2939
2686
9
2392
23
100
3039
2686
13
2392
27
1989/90
Maclnnes
#1**
400
3339
2744
22
2454
36
3339
2744
22
2454
36
800 MW - Coal
* Short-term purchases of peaking capacity are contemplated.
** TECO plans to own 400 MW of the 800 MW Maclnnes Unit 1. In addition, a short-term unit
power contract is anticipated similar to Big Bend Unit 4, which will reduce the 1989/90
percent reserve.
m O M € H O
> * X M > O
OOSHZO
W C M 52 R3 7*
I-* M M W H
ZH W C*1
OH •• t" Z
WO
H O •
M | ac H
/-s • pd oo
PC o
> > a o
H • Ut
i a so
H- H O U1
—' C g I
50 ^ Pi
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ECONOMIC IMPACT OF BIG BEND #4 IN 1983
100Z OIL DISPLACEMENT AT PROJECTED FUEL ESCALATION BATES1
I
K>
Ita-LmllMl
Cost of Capital
Total Annual
Savings
Fuel Prlee M/MBTO)
Fuel Cost SawlnM
Annual
During
Present
Cunul.Present
tear
on
Coal
A
MS/Tr.
Vlxe4 Charces (MS)
Construction
MI
Worth (H$?
Uorth (MS)'
1980
3
(3)
(3)
(3)
1981
4
(4)
(4)
(7)
1982
10
(10)
(8)
(15)
1983
22
(22)
(16)
(31)
1984
34
(34)
(23)
(54)
1983
623
286
337
35
62
90
10
(38)
(23)
(")
1986
710
312
398
42
100
105
(5)
(3)
(80)
1987
810
340
470
49
116
100
16
8
(72)
1988
923
371
552
58
138
95
43
20
(52)
1989
1053
404
649
68
161
90
¦ 61
25
(27)
1990
1200
440
760
80
190
86
104
39
12
1991
1344
480
864
91
216
81
135
46
58
1992
1505
523
982
103
245
77
168
52
110
1993
1686
570
1116
117
278
73
205
58
168
1994
1888
621
1267
133
316
69
247
63
231
1993
2115
677
1438
151
359
65
294
68
299
1996
2369
738
1631
171
406
62
344
72
371
.997
2653
804
1849
194
461
58
403
77
448
1998
2972
877
2095
220
522
55
467
81
529
1999
3329
956
2373
249
591
52
539
84
613
2000
3727
1042
2685
282
670
49
621
88
701
2001
4174
1135
3039
319
757
46
711
92
793
2902
4675
1238
3437
361
857
44
813
95
888
2003
5236
1349
3887
408
969
42
927
98
986
2004
$864
1470
4394
461
1095
39
1056
102
1088
2005
6568
1603
4965
521
1237
37
1200
105
1193
2006
7356
1747
5609
589
1399
36
1363
108
1301
2007
8239
1904
6335
665
1579
34
1545
111
1412
2008
9228
2076
7152
751
1783
32
1751
114
1526
2009
10335
2262
8073
848
2013
31
1982
117
1643
2010
11575
2466
9109
956
2270
30
2240
17119
120
1763
Escalation!
Coal - Year by Tear Escalation Through 1984; 9X Thereafter.
Oil - Year by Year Escalation Through 1984; 14Z (1985-1990); 12Z Thereafter.
Present Uorth Discount Bate Is 10.25Z.
January 1, 1981 Dollars.
T) DM £
-------
RESPONSE GCR-8
Based on a new trend in utility flue gas desulfurization (FGD) practice,
commercial grade gypsum manufacture by forced-oxidation operation of the
limestone-basa wet FGD is now becoming common. This is the first commer-
cial by-product FGD process alternative that is economically feasible for
many U.S. utilities.
In the 1970s, extensive application of such systems began in Japan. These
systems produce commercially marketable coarse-grained by-product chemical
gypsum in lieu of waste calcium sulfite sludge. This gypsum has been suc-
cessfully used in full scale production of wallboard, Portland cement, and
as an agricultural additive.
The Chiyoda CT-121 process, pilot-tested at Gulf Power Company's Plant
Scholz, successfully produced commercial grade gypsum. Part of this gypsum
was used in the production of wallboard at National Gypsum Company's Gold
Bond Building Products plant in Tampa, Florida, during September 1979.
Approximately 1000 full-size boards were produced. The wallboard met or
exceeded all specifications and was sent out for normal distribution into
the building industry.
Research-Cottrell, the manufacturer of the Big Bend Unit 4 FGD system, has
formed a company with Gebr. Knauf of Germany, a major producer of gypsum
products. FGD systems in Germany are at this time producing gypsum that
is being manufactured into conmercial wallboard. U.S. Gypsum and Celotex
are actively pursuing the use of FGD by-product gypsum in this country.
Several utilities are presently considering retrofitting the equipment re-
quired for producing gypsum.
The Big Bend Unit 4 FGD system is designed to produce gypsum meeting Gold
Bond's specifications. While no contracts have been signed, Gold Bond has
stated that it can utilize as much gypsum as Tampa Electric can supply.
Gold Bond presently must import natural (impure) rock gypsum from Nova
Scotia.
Tampa Electric Company presently sells its flyash to Florida Flyash, a sub-
sidiary of Florida Mining and Materials. This flyash is used in the pro-
duction of Portland cement, concrete, and masonry products. Flyash is a
usable by-product.
RESPONSE GCR-9
The gypsum and flyash are proposed to be marketed (see response to transcript
comment GCR-8 above). If flyash is disposed onsite it will be so in lined
disposal ponds. Although preliminary information indicates the leaching
potential of gypsum (if stored onsite) and bottom ash is minimal, a groundwater
monitoring program for the purpose of detecting leachate contaminates is
a condition of the NPDES permit. See also the response to transcript comment
GCR-7.
4-277
-------
RESPONSE GCR-10
The final draft NPDES permit will reflect the final determinations by the
State of Florida and EPA relative to variances for Units 1-3 and 4. EPA
Region IV does not expect that regulations will be promulgated under the
stated sections of the Act which will be more stringent than those already
promulgated (October 8, 1974) or proposed (October 14, 1980). These re-
quirements are included in the draft NPDES permit. However, to assure that
proper controls are exercised in the event that this expectation is in-
correct, the reopener clause has been included. See also the response to
transcript comment GCR-6 above.
RESPONSE GCR-11
See response to transcript comment GCR-6.
RESPONSE GCR-12
The DEIS reports the fact that the addition of Unit 4 to the Big Bend Station
will result in an expanded area of thermal impact to the benthic biota of
Hillsborough Bay. The increased thermal load is expected to enlarge the area
of adverse impact from about 46ha (115a) to 61ha (152a). The additional im-
pacts expected, however, are not viewed as unacceptable for reasons indicated
in EPA's tentative findings of fact and determinations reported in Appendix D
of the DEIS.
RESPONSE GCR-13
The DEIS recognizes that fine-mesh screening is a relatively new intake tech-
nology and that it has the potential to reduce entrainment effects associated
with once-through cooling systems. The potential use of such technology was
demonstrated by the applicant through a lengthy series of testing and modifi-
cations to a prototype fine-mesh screening device. For example, the DEIS
reports that the screening device was 56 percent effective in removing eggs
and larvae of fish and shellfish from the cooling water source. Since this
finding, engineering changes in the screening device have provided for an
increased screening efficiency. With the installation of full-scale fine-
jnesh screening structures on Units 3 and 4, the operational success of the
two installations will be monitored and assessed. Requirements for such
testing and assessments are indicated in Part III of the Draft NPDES Permit
reported in Appendix A of the DEIS.
The level of entrainment associated with any conventional generating units
is primarily a function of the volume of cooling water required. As stated
in the DEIS, each of the four generating units at the Big Bend Station will
require approximately 537 cfs cooling water flow. Hence, each unit would
be expected to effect the same level of entrainment impact.
4-278
-------
RESPONSE GCR-14
See response to written conment HEC-4.
RESPONSE GCR-15
Comment noted. This comment appears to summarize the commentor's presenta-
tion. Attention is directed to the responses previously given for specific
issue areas.
RESPONSE GCR-16
See response to transcript conment GCR-10.
RESPONSE ST-1
See response to written comment SC—7.
RESPONSE RP-1
See response to written comment HEC-4.
RESPONSE RP-2
See response to written conment CDC-3 and HEC-5.
RESPONSE RP-3
See response to written comment HEC-6.
RESPONSE RP-4
See response to transcript comment GCR-13.
RESPONSE MK-1
See response to written comment HEC-2.
RESPONSE MK-2
See response to written conment HEC-3.
4-279
-------
RESPONSE MK-3
See response to written coument HEC—3.
RESPONSE MK-4
See response to written comment HEC-3.
RESPONSE MK-5
Conment noted.
RESPONSE LR-1
See response to written comment SC-7.
RESPONSE JM-1
Comnent noted.
RESPONSE JM-2
See response to written comnent SC-7.
RESPONSE JM-3
In 1980, total sales of energy by TECO to industrial customers amounted
to 4,290 GWH. Sales to phosphate customers accounted for 3,276 GWH, or
about 76 percent of that total.
RESPONSE JM-4
Comnent noted. See also response to written comment SC-7.
RESPONSE JM-5
The various reserve percentages referenced in this comment can be explained
with the aid of the tables included as part of response to transcript comnent
GCR-3 above. These tables are Exhibit HAT-1 to Mr. H. A. Turner's prepared
written testimony submitted to the Florida Public Service Commission at the
Big Bend 4 Need Certification hearing.
In the winter of 1985/1986, forecasted firm load is 2,225 MW and forecasted
total load is 2517 MW (total load equals firm load plus interruptible load).
System capability is 2,522 MW (without Big Bend 4) and 2,731 MW (with Big
Bend 4. Note: TECO will retain 209 MW of 417 MW from Unit 4 at this time).
4-280
-------
Thus, without Big Bend 4, percent reserves for firm load are 13% (2,522/
2,225). With Unit 4, percent reserves for firm load are 23% (2,731/2,225);
and for total load are 9% (2,731/2,517).
RESPONSE JM-6
See response to written comment SC-7.
RESPONSE BC-1
Comment acknowledged. Energy alternatives were discussed in the DEIS (Sec-
tion 2.3) and TRD (Section 3.2).
RESPONSE BC-2
See response to written comment SC-7.
4-281
-------
Chapter 5
LIST OF PREPARERS
Robert B. Howard
Dario J. Dal Santo
Clara J. Delay
Russell Todd
Charles H. Kaplan
Lloyd Wise
Henry G. Strickland
Delbert B. Hicks
Reginald G. Rogers
D. Brian Mitchell
Lewis Nagler
Michael J. Hartnett
Gail Mitchell
Richard Nugent, Jr.
George Fisher
Arnold Solomon
William Weiss
Gary Friday
Environmental Protection Agency
Acting Chief
E1S Preparation Unit
Project Officer
(1980-pub1icat ion)
Project Officer
(1979-1980)
Project Officer
(1978-1979)
NPDES Permit
Water Quality
Biology and Ecology
Biology and Ecology
Air Resources
Air Resources
Residuals Management
Ground Water
NUS Corporation
Project Manager,
Marine Science (PhD)
Assistant Project Manager,
Meteorology (MS)
Air Quality (1980-publication)
Aerospace Engineering (BS)
Air Quality (1979-1980)
Marine Science (MS)
Aquatic Ecology
Fisheries and Wildlife (PhD)
Terrestrial Ecology
5-1
-------
Allan Toblin
Linda Robinson
Stuart Miner
Irvin Samec
Ronald Stoner
Arnold Katterhenry
William Ellison
E. Robert Smith
William Greenaway
For information on the material
Dario J. Dal Santo at (404) 881
Chemical Engineering (MS)
Hydrology
Earth Sciences (BS)
Geology
Political Science (BA)
Socioeconomics (1979-1980)
Sociology (BA)
Socioeconomics (1980-publication)
Meteorology (BS)
Meteorology
Nuclear Engineering (MS)
Engineering
Mechanical Engineering (MS)
Gas Cleaning
Chemical Engineering (BS)
Utility Aspects
Chemical Engineering (BS)
Wastewater Engineering
presented in this section, contact
7458 (FTS/257-7458).
5-2
-------
Chapter 6
COORDINATION LIST
The following Federal, State, and local agencies and interest groups have
been requested to comment on this impact statement:
Federal Agencies
Coast Guard
Corps of Engineers
Council on Environmental Quality
Department of Agriculture
Department of Commerce
Department of Education
Department of Energy
Department of Health and Human
Services
Department of Housing and Urban
Development
Department of the Interior
Department of Transportation
Economic Development Administration
Federal Aviation Administration
Federal Highway Administration
Fish and Wildlife Service
Food and Drug Administration
Forest Service
Geological Survey
Heritage Conservation and Recreation
Services
National Park Service
Public Health Service
Soil Conservation Service
Members of Congress
Honorable Lawton Chiles Honorable Paula Hawkins
U.S. Senate U.S. Senate
Honorable Sam M. Gibbons Honorable Andrew Ireland
U.S. House of Representatives U.S. House of Representatives
Honorable William McCollum Honorable C. W. Young
U.S. House of Representatives U.S. House of Representatives
State Agencies
Honorable D. Robert Graham,
Governor
Coastal Coordinating Council
Department of Agriculture
Department of Commerce
Department of Community Affairs
Department of Envirormental
Regulation
Department of Health and
Rehabilitative Services
Department of Natural Resources
Department of the State
Department of Transportation
Geological Survey
Game and Freshwater Fish
Commission
Local Agencies
Southwest Florida Water Management District
Tampa Bay Regional Planning Council
Southwest Florida Regional Planning Council
Greater Tampa Chamber of Commerce
Tampa Port Authority
City of Tampa
City of St. Petersburg
Hillsborough County Environmental Protection Commission
6-1
-------
Interest Groups
Florida Audubon Society
Florida Sierra Club
Izaak Walton League of America
Florida Lung Association
ManaSota-88
Florida Defenders of the Environment
Florida Wildlife Federation
Hillsborough Environmental Coalition
League of Women Voters
6-2
-------
Appendix A
NPDES PERMIT AND RATIONALE FOR BIG BEND UNIT 4
-------
The draft NPDES permit for Unit 4 contained in this
Appendix is designed for combination with the draft permit
for Units 1-^ contained in Appendix B. This Appendix con-
tains only those requirements which are specificial ly app-
licable to Unit 4, but does not include any 6f the "boiler-
plate" requirements of Section II which are included in
Appendix B> Due to the different administrative proced-
ures required for new sources (Unit 4) and existing sources
(Units 1-3), separate applications were submitted and dif-
ferent NPDES Numbers assigned. However, only one permit
will be issued for all four units after completion of the
Environmental Impact Assessment procedures applicable to
Unit 4. NOTE: Changes made to the July 9, 1981, Draft
Permit contained in the DEIS (except for the November 20,
Draft date) are indicated by a bar in the margin as shown
to the right.
A-l
-------
Permit No.t FL0037044
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
141 COURT LAND *TBrtT
ATLANTA. OCOROIA >OJ*J
' AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Clean Water Act, at amended
(33 U.8.C. 1251 at. aeq; the "Act"),
Tampa Electric Company
Post Office Box 111
Tampa, Florida 33601
is authorised to discharge from a facility located at
Big Bend Station
Unit A
Big Bend Road
North Ruskin, Florida 33570
to receiving waters named
Hillsborough Bay
in accordance with affluent limitations, monitoring requirements and
ether conditions sat forth in Parts I, XI, and III hereof. The permit
consists of this cover sheet, Part I j pages(s), Part II 12 page(s)
and Part III 3 paga(a).
This permit ahall become affective on
This permit and the authorisation to discharge shall expire at
¦itfnight, , i987
Data Signed
A-2
-------
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During tne period beginning on the effective date of this permit and lasting through the term of this permit,
the permittee shall monitor outfall (s) serial number (s) 007 If - Plant Intake
Characteristic
Flow—m3/Day (MGD)
Intake Temperature C( F)
Additional Monitoring
'Monitoring Requirements
Measurement
Frequency
Sample
Type
Continuous Pump Logs
6/day Logs
See Part III.E
After the date of start of Unit A intake pump testing, intake screen wash water from Units 3 and A
shall be discharged to the east end of the canal north of the intake canal or to a location accept-
able to EPA and the State of Florida and may be discharged without limitations and monitoring re-
quirements except for biological monitoring required by Part III.M. Any bypasses of the fine mesh
screens shall be reported to EPA When submitting quarterly DMR's.
¦» *rS
" B>
3 <*»
=• <*
Samples taken in compliance with the monitoring requirements specified above shall lie taken at the following l-. : »t;on(s):
Plant Intake except that temperature shall be at the condenser inlet(s). S
i
3 **
o
¦fN
1/ This serial number is assigned for identification and monitoring purposes only, except as noted £
above for discharge of intake backwash.
-------
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through the term of this permit,
the permittee is authorized to discharge from outfaH(s) serial number(s) 008 - Once-through condenser cooling water
from Unit 4 to the plant discharge canal.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations
kg/day (lbs/day) Other Units (Specify)
Daily Avg Daily Max Daily Avg Daily Max
Monitoring Requirements
Measurement Sample
Frequency Type
Note: There will be no changes to the once—through cooling water pages (1-1 and 1-2) for Units 1,
2 and 3, except for the incusion of serial number "008" and Unit "4" at applicable points
on those pages.
-------
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through the term of this permit,
the permittee is authorized to discharge from outfall(s) serial number(s) 009 - Boiler blowdown from Unit 4 to
Serial number 008.
Such discharges shall be limited and monitored by the (permittee as specified below:
Effluent Characteristic
Discharge Limitations
kg/day (lbs/day)
Daily Avg Daily Max
Flow—m3/Day (MGD) —
Total Suspended Solids 4.9(10.8)
Oil and Grease 2.5(5.4)
Additional Monitoring
Other Units (mg/1 )
Daily Avg
16.4(36.1) 30
3.3(7.2) 15
See Part III.E.
Daily Max
100
20
Monitoring Requirements
Measurement
Frequency
Sample
Type
Daily Daily Logs
2/.month Grab
2 /month Grab
See Part III.E.
The pH shall not be less than n/A standard units nor greater than N/A standard units and shall he nionitored N /A.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at
the following location(s) : nearest accessible point after final treatment but prior to mixing
with other plant wastes.
-------
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through the term of this permit,
the permittee it authorized to discharge from outfall(t) serial number(s) 010 - Bottom ash system blowdown to
Serial number 008.
Such dischargee shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Discharge Limitations
kg/day (lbs/day) Other Units (mg/1 )
Daily Avg
Daily Max
Daily Avg
Daily Max
Monitoring Requirements
Measurement
Frequency
Sample
Type
Flow—m3/Day (MGD)
Total Suspended Solids
Oil and Grease
Additional Monitoring
13.0(28.8)
6.5(14.4)
43.5(96.0)
8.7(19.2)
30
15
100
20
See Part II1.E.
Continuous
2/week
2/month
Recorder
Grab
Grab
See Part III.E.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored
2/week on a grab sample.
There dull be no discharge of floating solids or visible foam in other than trace amounts*
Samples taken in compliance with the monitoring requirements specified above shall be taken al the following location(s)
nearest accessible point after final treatment but prior to mixing with other plant wastes.
-------
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on start of discharge and lasting through the term of this permit,
the permittee is authorized to discharge from outfall(s^ serial number(s) Oil - Flue gas desulfurization system
blowdown to Serial number 008.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Discharge Limitations
kg/day (lbs/day) Other Units (mg/1 )
Daily Avg
Daily Max
Daily Avg
Daily Max
^Monitoring Requirements
Measurement
Frequency
Sample
Type
>
i
Flow—m3/Day (MGD) —
Total Suspended Solids 6.7(14.8)
Oil and Grease 3.3(7.4)
Additional Monitoring
22.3(49.2) 30 100
4.5(9.8) 15 20
See Part III.E.
Continuous Recorder
2/week Grab
'2/month Grab
See Part III, E.
$
rv>
3
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored
2/week on a grab sample.
-¦» Tj x
a o» >
: * 30
- it
There shall be no discharge of floating solids or visible foam in other than trace amounts:
Samples taken in compliance with the monitoring requirements specified above shall be taken al the following location(s): ^
nearest accessible point after final treatment but prior to mixing with other plant wastes. g
o
OJ
o
-------
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
< 2>
&
E>.
a
During the period beginning on Che start of discharge and lasting through the term of this permit,
the permittee is authorized to discharge from outfall(s) serial number(s) 012 and 013 - Construction dewatering waste
discharge to plant intake and discharge canals , respectively.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Total Suspended Solids
Discharge Limitations
Other Units (ag/1)
Daily Max
50
Monitoring Requirements
Measurement Sample
Frequency Type
1/week Grab
The pH shall not be less than N/A standard units nor greater than N/A standard units and shall be monitored N/A.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
2 %
ft
5B _
O
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): ^ ^
Prior to discharge to canals.
r1
o
o
u>
-------
PART I
Page 1-7
Pctmlt No. FL0037044
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent limitations specified for
discharges In accordance with the following schedule:
a. Achieve effluent limitations- On effective date or start of
discharge as applicable.
f. Priority pollutant data (Part I1I.G.) - Submit by 12 months
after commercial operation date of Unit 4 .
g. Flow report (Part III.R.) - Submit by 15 months after commercial
operation date of Unit 4.
h. Groundwater Monitoring Program (Part III.I.)
(1) Implement - One year prior to operation of Unit 4.
(2) Reports - Quarterly with DMR's .
i. Erosion and Sediment Control Program (Part III.J.)
(1) Implement - By start of on-site construction
(2) Reports -
(a) Quarterly with DMR's during first year.
(b) Semiannually, thereafter.
j. Thermal Model (Part III.K.) — Verification six months prior
to operation of Unit 4.
k. Installation of fine mesh screen (Part III.L.) - Prior to Unit 4
pump testing «
1. Biological Monitoring (Part III.M.) -
(1) Submit study plan - 18 montns prior to commercial operation
date of Unit 4.
(2) Implement - one year prior to operation of Unit 4.
2. No later than 14 calendar daya following a date identified in the above schedule of
compliance, the permittee shall submit either a report of progress or, in the case of
specific actions being required by identified dates, a written notice of compliance or
noncompliance. In the latter case, the notice shall include the cause of noncompliance,
any remedial actions taken, and the probability of meeting the next scheduled
requirement.
DRAFT
JAN 1 X 1992
A-9
-------
DRAFT
PART III
JAN 11 1982
PART III
OTHER REQUIREMENTS
E. Additional monitoring of the plant intake (007), Unit 4 once-through cooling
water discharge (008) , boiler blowdown (009), bottom ash blowdown (010), and
flue gas desulfurization system blowdown (011) shall be conducted at a fre-
quency of 2/month for the first 12 months following commercial operation of
Unit 4. and 1/month thereafter. Samples shall be two grab composites with
grabs taken not less than two hours apart. Parameters shall include total
arsenic, cadmium, chromium # copper, iron, lead, mercury, nickel , selenium
F. There shall be no discharge to waters of the United States of low volume
wastes (except for FGD system blowdown (011) as otherwise provided herein) ;
any water wash or chemical metal cleaning wastes; runoff from plant con-
struction, coal plle(s), gypsum storage or disposal areas, fly ash storage
or disposal areas (including that from rainfall events exceeding the 10-year ,
24-hour storm); or fly ash sluice waters or blowdown.
G. Not more than 12 months after the Commercial Operation Date of Unit 4,
permittee shall submit representative data as included in 40 CFR Part
122.53 (d)(7)(H), (ill) and (iv) for serial numbers 007, 008, 009 ,
010, and 011. In the event than any pollutant is present at an unac-
ceptable level, this permit shall be modified , or alternatively , revoked
and reissued, to comply with any applicable provisions of the Clean
Water Act. A twelve month period is to allow stabilization of waste
streams before sampling.
H. Subsequent to the commercial operation date of Unit 4,the
permittee shall conduct a detailed evaluation of inplant
waste discharges (009, 010 and 011) to confirm design flow
data. A report of this evaluation shall cover a one-year
period after startup of the unit and shall be submitted not
later than 15 months after the commercial operation date.
In the event that actual flow data is significantly differ-
ent fTom design data, the permit may be modified by the
Director, Enforcement Division.
I. The Permittee shall implement a groundwater monitoring
program approved by EPA and the State not later than one
yfa?, prior to °Peratlon of Big Bend Unit 4. Monitoring
shall be performed in accordance with the approved plan.
Reports shall be submitted to EPA with quarterly Discharge
Monitoring Reports.
and zinc
A-10
-------
DRAFT
PART III
Page III-2
Permit No. FLQ03704^
JAN 11 1982
Should the reports demonstrate significant contamination
of groundwater is occurring, the Permittee shall
immediately consult with EPA and the State and
expeditiously institute corrective measures acceptable to
EPA and the State to mitigate the contamination. These
measures may include but are not necessarily limited to:
sealing, relocating, or altering operations of the
wastewater treatment ponds, ash ponds, FGD byproduct/ash
storage areas, or coal piles. If the reports demonstrate
that no significant contamination is occurring from
commercial operation of Unit 4, the Permittee after
consultation with and approval by the Director,
Enforcement Division, may reduce or eliminate the
monitoring program.
In the event that changes in the monitoring program become
necessary, such changes shall be approved by the Director,
Enforcement Division, and the State Director prior to
institution.
j. The Permittee shall implement a construction erosion and
sedimentation control program approved by EPA not later
than the start of onsite construction. Monitoring
reports shall be submitted quarterly with the Discharge
Monitoring Reports during the first year of construction
and semiannually thereafter. Erosion and sedimentation
control practices shall be consistent with sound
engineering practices such as those contained in
"Guidelines for Erosion and Sediment Control Planning and
Implementation," EPA-R2-72-015 (August, 1972) or
"Processes, Procedures, and Methods to Control Pollution
Resulting from all Construction Activity," EPA-430-73-007
(October, 1973).
K. The Permittee shall validate the area to be impacted by
the thermal plume from Units 1-4 by submitting a verified
thermal dispersion model at least six months prior to
commencement of operation at Unit 4. EPA, the State, and
TECO shall agree to a program to ensure an appropriate
model is selected, verified, and utilized.
L. The fine mesh screen for the Units 3 & 4 intake structures
and the organism return mechanism shall be installed and
operational prior to Unit 4 pump testing.
M. a biological monitoring program shall be implemented at
least one year prior to operation of Unit 4. The program
shall be designed so that the potential impacts of Unit 4,
in conjunction with Units 1-3, on the benthos of the Tampa
Bay system and the survivability of organisms during
operation of the full-scale fine mesh screens and organism
return mechanism can be assessed. The program shall be
approved by EPA and the State and shall be conducted for
one year following start of operation of Unit 4. A
proposed program shall be submitted for EPA and State
approval no later than 18 months prior to commercial
operation of Unit 4 (currently scheduled for the spring of
1985). A_„
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DRAFT
JANU 1982
PART III
Page III-3
Permit No. FL0037044
To alleviate potential adverse impacts to the West Indian
manatee, an endangered species, the Permittee shall post
"Slow Boat Speed" signs in the discharge canal and shall
close the boat ramp in the discharge canal from November
15 to March 30 as recommended by the U. S. Fish and Wild-
life Service (USFUS).
The Permittee shall ensure that the mangrove swamp system -
located along the southwestern coastal portion of the site
is not disturbed as a result of construction and operation
activities associated with the Big Bend complex.
Unless a preceding NPOES condition specifies otherwise,
the Permittee shall implement its proposed project in
complete accordance with the proposed action described in
the Draft and Final EIS. This shall not preclude
implementation of additional or more stringent conditions
required by local or state governmental bodies. Should
the applicant desire significant modification, such
modification must be approved by EPA prior to initiation.
The State of Florida Department of Environmental Regulation has certified the
discharge(s) covered by this permit with conditions (Attachment B). Section 401
of the Act requires that conditions of certification shall become a condition of
the permit. The monitoring and sampling shall be as indicated for those para-
meters included in the certification. Any effluent limits and any additional
requirements specified in the attached state certification which are more stringent
supersede any less stringent effluent limits provided herein. During any time
period in which the more stringent state certification effluent limits are stayed
or inoperable, the effluent limits provided herein shall be in effect and fully
enforceable. (Note: Certification to be provided before permit issuance.)
A-12
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JAN 11 1982
Big Bend Station
Unit 4
Permit Rationale
NPDES No. FL0037044
I. Applicable Regulations
A. Federal performance standards for new sources for
the steam electric power generating point source
category (40 CFR 423.15) as promulgated on October
8, 1974, with proposed revisions published on
October 10, 1980T (Tee Environmental Impact
Statement (EIS) Appendix J.)
B. Florida Water Quality Standards .Chapter 17-3,
Florida Administrative Code. (See EIS Appen-
dix K). The receiving water 1s classified as
Class III - Recreation - Propagation and Manage-
ment of F1sh and Wildlife Surface Waters.
II. Effluent Limitations
A. NPDES Serial Number 008 - Once-through cooling
water.
1. Temperature: A weekly average of 9.3°C(16.
8°F) 1s Included based on the 316(a) De-
termination, historical data from Units 1-
3, and expected future operating levels.
2. Total residual oxidants (total residual
chlorine): Limitation of 0.20 mg/1 1s
based on Florida Water Quality Standards
and 1s more stringent than the promulgated
effluent standards (40 CFR 423.15(h)). (fe-
talis of the rationale are Included 1n
the Environmental Impact Statement. A de-
tailed chlorine minimization study 1s un-
derway on Units 1-3. Future limitations
consistent with proposed standards (40 CFR
423.15(g) througn (1)) are Included 1n the
draft permit. Additionally, a decay study
on oxidant concentrations 1n the discharge
canal Is required by the Permit. Subsequent
to completion of these studies, Permit modifi-
cation can be pursued should conditions require
further reduction 1n total residual oxidant
level.
A-14
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NPDES Serial Number 009 - Boiler blowdown.
1. Limitations are as required by promulgated
40 CFR 423.15(g) and proposed 40 CFR 423.15(c),
except that Iron and copper limitations
have not been Included. Historical data from
Units 1-3 Indicate that Iron and copper have
been significantly below the 1.0 mg/1 effluent
requirement. A best professional judgement
has been made that future concentrations of
Iron and copper from Unit 4 should be no
greater than historical- levels from Units 1-3.
Additionally, proposed standards have de-
leted boiler blowdown as a separate cate-
gory and have Included 1t 1n the low vol-
utin waste category, 40 CFR 423.15(c),
which 1s not subject to Iron and copper
limitations.
2. Additional monitoring requirements are In-
cluded to assure conformance with applicable
Water Quality Standards and with probable
variance requirements (See Item G, below).
NPDES Serial Number 010 - Bottom ash system blow-
down .
1. Limitations are as required by promulgated
40 CFR 423.15(d) for a recycled ash handling
system. Although proposed 40 CFR 423.15(e)
would allow use of a once-through bottom ash
transport system, such a system 1s not con-
sidered viable at the B1g Bend Site for Unit
4 (adequate fresh water 1s not available and
a salt water system 1s not environmentally
desirable, based on data from the slag pond
for Units 1-3).
2. Additional monitoring requirements are In-
cluded to assure conformance with applicable
Water Quality Standards and with probable
variance requirements (See Item G, below).
NPDES Serial Number Oil - Flue gas desulfurlzation
system blowdown.
1. Limitations are as required by promulgated
and proposed 40 CFR 423.15(c) for low volume
wastes.
2. Additional monitoring requirements are In-
cluded to assure conformance with applicable
Water Quality Standards and with probable
variance requirements (See item G, Below).
A-15
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-3-
E. Calculation of quantity limitations for Serial
Numbers 009, 010, and Oil. Quantity limitations
are calculated as follows:
Quantity (lbs/day)«8.345 x Flow (MGD) x Allowed Concentration (mg/1)
where: 8.345 1s the appropriate conversion factor,
flows are expected discharge flows as provided by
the applicant (flow of ash sluice blowdown 1s five
percent of the ash sluice flow for serial 010), and
where concentrations (mg/1) are as provided In appli-
cable subsections of 40 CFR 423.15, as noted below.
30-day Average 24-hour Average
(Dally Average) (Pally Maximum)
Total Suspended Solids 30 100
011 and Grease 15 20
F. NPDES Serial Number 012 and 013 - Construction
dewaterlng waste. Limitation 1s based on best
professional judgement.
G. Variance. Ambient levels of arsenic, cadmium,
chromium, copper, Iron, mercury, nickel, and se-
lenium exceed Florida Water Quality Standards
Criteria 1n the Bay Waters. Therefore, the ad-
dition of any of these pollutants, regardless
of how little the concentration exceeded the am-
bient level and/or the state criterion, would
technically violate the water quality standards.
Due to the relatively low expected addition of
these pollutants, the applicant has requested
and a variance to the state criteria for a two-
year period after the start of commercial opera-
tion has been granted. During this period the
permittee will be required to (1) monitor the
discharge of pollutants, (2) operate the FGD
blowdown treatment system so as to minimize the
metal content of the discharge from the system,
(3) explore the practicability of treating the
boiler blowdown 1n the FGD treatment system when
there 1s capacity 1n the system to accommodate
that blowdown and (4) submit reports of the above
studies and analyses after the first year and at
least twenty months after the start of commer-
cial operation. Additional Information on ambient
condl tlons and variance discussions are Included
in the Environmental Impact Statement.
A-16
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-4-
H. Proposed Permit Period: Five years.
The NPDES permit requires compliance with the
most stringent requirements of either the pro-
mulqated (October ft, 1974) or proposed (Octo-
ber 10~1980) standards of performance for new
sources (40 CFR 423.15). Data on priority
pollutants has been submitted on Units 1-3, but
samples can not be collected from Unit 4 waste
sources since the plant Is not yet 1n operation.
Evaluation of expected effluent quality .sub-
mitted by the applicant for Unit 4 and actual
analyses from Units 1-3, have led the permit
writer to the tentative conclusion that ad-
ditional treatment for prirolty pollutants 1s
not likely for any pollutants (other than
heavy metals as described 1n Item 6 above) and
that a full five-year permit should be issued.
However* to assure that this judgement is cor-
rect, the permittee will be required to sub-
mit priority pollutant data, not later than
one year after the commercial operation date
of Unit 4. Additionally, a reopener clause
1s included 1n the permit (Part III.G.) in
the event that excessive levels of priority
pollutants are found.
A-17
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Appendix B
NPDES PERMIT AND RATIONALE FOR BIG BEND UNITS 1-3
-------
The draft NPDES Permit for Units 1-3 contained in this
Appendix is administratively complete^(contains Parts 1, II
and III), but is designed for combination with the draft per-
mit for Unit 4 contained in Appendix A. Due to the differ-
ent administrative procedures required for new sources
(Unit 4) and existing sources (Unit 1-3), separate appli-
cations were submitted and different NPDES Numbers assigned.
However, only one permit will be issued for all four units
sfter completion of the Environmental Impact Assessment
procedures applicable to Unit 4. NOTE: Changes made to the
July 9, 1981, Draft Permit contained in the DEIS (except for
the November 20 Draft date) are indicated by a bar in the
margin as shown to the right.
B-l
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Permit Mo.: FL0000817
,TES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
I4S COUHTLAND WTRfCT
ATLANTA. OCOROIA |«M>
¦" AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance vith the provision* of the Clean Water Act, ai amended
(33 U.6.C. 1251 et. acq; the "Act"),
Tampa Electric Company
Post Office Box 111
Tampa, Florida 33601
la authorised to discharge from a facility located at
in accordance vith effluent limitationa, monitoring requirements and
ether conditions aet forth in Parta I, II, and III hereof. The permit
consists of this eover sheet, Part I 7 pages(s), Part II 12 page(s)
and Part III lpage(s).
This permit shall become effective on
This permit and the authorisation to discharge shall expire at
aidnight, t 1987
Date Signed
Big Bend Station
Units 1-3
Big Bend Road
North Ruskln , Florida 33570
to receiving vaters named
Hillsborough Bay
B-2
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EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting through the term of this permit,
the permittee is authorized to discharge from outfall(s) serial number(s) 001, 003 and 004 - Once-through
condenser cooling water from Units 1, 2 and 3, respectively,to the plant discharge canal (0051/).
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Plant Discharge temperature °C(°F)
Plant temperature rise °C(*F)
Total residual oxidants (mg/1)
Time of TRO discharge (minutes/day)
Discharge Limitations
Weekly Daily
Average Maximum
N/A
9.3(16.8)
SEE BELOW
SEE BELOW
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=1
3
Monitoring Requirements 1/
Measurement
Frequency
Continuous
6/Day
1/Week
1/Week
Sample
TyPe
Recorder
Calculations
Multiple Grabs
Determinations
Intake screen backwash is permitted without limitation or monitoring requirement
There shall be no discharge from dilution pump(s) without prior approval by the Director, Enforcement Division,
except that permittee is authorized to operate each p>ump for maintenance purposes not to exceed one-half hour ppr
week.
Discharge of total residual oxidants(TRO) shall not exceed a maximum
instantaneous concentration of 0.20 mg/1 at the outlet corresponding to an individual unit during any one day.
TRO shall not be discharged (except as noted below) from any unit for more than two hours in any one day and
not more than one unit may discharge TRO at any one time. Notwithstanding these requirements, permittee shall
institute the chlorine minimization study in accordance with plan of study submitted on February 25, 1981
and amended June 2, 1981. Status reports shall be submitted quarterly with Discharge Monitoring Reports (DMR's)
indicating tests conducted and results obtained during the quarter with the first report due on October 28,
1981. Summary reports shall be submitted annually with the first report due on August 31, 1982. The summary
report shall be in lieu of the April - June quarterly report. Chlorine use shall be minimized consis-
tent with study results.
Permittee shall expeditiously, but in no case later than May 31, 1982,conduct a decay study
of TRO in the discharge canal during a period when either Unit 2 , or Unit 3, but not both,
is in operation.
(CONTINUED)
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting through the term of this permit, the
permittee is authorized to discharge from outfall(s) serial number(s) 001, 003 and 004 - Once-through
condenser cooling water from Units 1, 2 and 3, respectively, to the plant discharge canal (005hi), fCONTINUED) .
Not later than three years after promulgation or July 1, 1987, whichever is earlier,
there shall be no discharge TRO. Notwithstanding the foregoing, the permittee may,
upon showing the Director, Enforcement Division, that the facility must use chlorine
for cooling water system biofouling control, discharge the minimum amount of TRO nec-
essary to operate the facility. In no case shall TRO be discharged for more than two
hours per day per discharge point nor shall the TRO exceed an instantaneous maximum of
of 0.14 mg/1 nor 0.20 mg/1 Instantaneous maximum to comply with Florida Water Quality
Standards requirements, whichever is less. Not later than one year after promulgation,
permittee shall submit a proposed implementation schedule to expeditiously provide con-
trols necessary to comply with these requirements. Note: In the event that BAT regu-
lations for control of TRO or chlorine are promulgated in a manner inconsistent with
the October 14, 1980, proposed guidelines , requirements of this paragraph will be modi-
w fied consistent with the promulgated regulations (40 CFR 423).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s) : Temperature in the plant discharge canal (005 1/) and total residual oxidants at the outlet
corresponding to an individual unit prior to entering the plant discharge canal (end of individual flumes).
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— Serial number 005 has been assigned for monitoring and reporting of flow, discharge temperature and
temperature rise for the plant and shall be located after combination of serial numbers 001, 003 and
004. Reporting of flow and discharge temperature shall be provided as minimum, average and maximum ?
based on average values for each calendar day for each month. Temperature rise shall be provided as §
the maximum weekly average value for each month based on calendar week average values. Records of §
average intake and discharge temperatures for each calendar day shall be maintained but not submitted.
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EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting through the term of this
permit, the permittee is authorized to discharge from outfall(s) serial number(s) 002 - Slag pond effluent
to discharge canal (includes boiler blowdovm).
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Flow-m /Day(MGD)
Total Suspended Solids W
Oil and Grease
Total Arsenic
Total Cadmium
Total Chromium
Total Copper
Total Iron
Total Lead
Total Mercury
Total Uickel
Total Selenium
Total Zinc
Hot later than March 16 ,
systems , including costs
Discharge Limitations
Monitoring Requirements
kg/day(lbs/day)
Other Units(rag/1)
Measurement Saraple
Daily Avg
Daily Max
Daily Avg
Daily Max
Frequency Type
Continuous Recorder
~TJ
2/
6.0 3/
~~24 3/
5/week 24-hr.Composite
470(1030)
620(1370)
15
20
2/month Grab
N/A
N/A
N/A
0.30
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
0.032
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
0.24
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
0.14
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
3.44
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
N/A
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
0.1
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
0.22
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
0.32
5/two mo. 4/ 24-hr. Composite
N/A
N/A
N/A
N/A
5/two mo. 4/ 24-hr. Composite
1983, permittee shall evaluate alternative suspended metals removal
and feasibility, and submit a report on this
evaluation.
6.0 standard units nor greater than 9.0
standard units
and shall be monitored
1/week on a grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts,
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w£ionr«vn P« wi4th the ~»itoring requirements specified above shall be taken at the following « m A
location(8). Pond effluent prior to entering plant discharge canal. a 1
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting through the term of this permit,
the permittee is authorized to discharge from outfall(s) serial number(s) 002 - Slag pond effluent to discharge
canal (Includes boiler blowdown). (CONTINUED)
J_/ Total suspended solids data shall be tabulated, plotted vs. time, and submitted monthly
by the 28th day of the following month.
2/ The quantity of total suspended solids discharged shall not exceed the quantity deter-
mined by multiplying the flow of slag sluice water and boiler blowdown times the differ-
ence between Intake and discharge concentrations.
3/ Limitations have been applied on a net basis at the request of the permittee. Net values
shall be computed by subtracting the intake value from the discharge value for the same
date. In computing net values , negative values shall be considered zero. The Director ,
Enforcement Division may , on request by the permittee or based on a review of the permit
file, modify the net effluent limitations in accordance with 40 CFR 122.15.
4/ Monitoring shall be conducted for five consecutive days each two months.
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting through June 30, 1982,
the permittee is authorized to discharge from outfall(s) serial number(s) 006 - Coal pile runoff to plant
intake canal.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic Discharge Limitations
Instantaneous
Maximum
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3
Monitoring Requirements!/
Measurement Sample
Frequency Type
Flow-m3/Day(MGD)
Total Suspended Solids(mg/l)
Pond Water Level
N/A
50 y
N/A
N/A
2/week
3/week 1/
N/A
Grab
Staff Gage
W
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The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored
2/week on a grab sample hit 2/.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following
location(s): Nearest accessible point after final treatment but prior to actual discharge ot mixing
with the receiving waters.
Subsequent to June 30, 1982, there shall be no discharge or bypass of coal pile runoff to waters of the
U. S. or to any waste stream entering such waters.
T3 T3
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting through the term of this permit,
the permittee shall monitor outfall(s) serial number(s) 007 1/ - Plant Intake
Characteristic
Flow—m*/Day (MGD)
Intake Temperature C( F)
Total Suspended Solids(mg/1) 2/
Heavy Metals (See Below)
Monitoring Requirements
Measurement
Frequency
Sample
Type
CD
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Continuous Pump Logs
6/day Logs
5/week 24-hour Composite
5/two months 24-hour Composite
Intake screen wash water may be discharged without limitations and monitoring requirements to the
plant intake canal.
Monitoring for heavy metals in the plant intake shall be conducted for five consecutive days each two
months on composite samples. Parameters collected shall include total arsenic* cadmium, chromium,
copper, iron, lead, mercury, nickel, selenium and zinc. All data values shall be submitted.
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Samples taken in compliance with the monitoring requirements specified above shall lie taken at the following ior-aiion(s): ^
Plant Intake except that temperature shall be at the condenser inlet(s).
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\j This serial number is assigned for identification and monitoring purposes only, except as 00
noted above for discharge of intake screen backwash. *"*
2/ Total suspended solids data shall be tabulated, plotted vs time, and
submitted monthly by the 28th day of the following month.
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DRAFT
JNt l l
PART I
Page 1-7 0
Permit No. FL0000817
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent limitations specified
for discharges in accordance with the following schedule:
a. Achieve effluent limitations - On effective .date or start
of discharge as applicable.
b. Chlorine minimization (001, 003 and 004)
(1) Implement - July 1, 1981.
(2) Status Reports - Quarterly with DMR's, with first report
due in October 1981 (3 per year).
(3) Summary reports - Annually, with the first report due
on August 31, 1982*
(A) Implementation schedule (chlorine reduction controls) -
One year after promulgation.
c. Slag pond treatment evaluation (002) - Report submittal by
March 16, 1983.
d. Oxidant decay study (003 or 004) - Implement expeditiously,
but no later than May 31, 1982.
e. Terminate discharge (006) - June 30, 1982.
2. No later than 14 calendar days following a date identified in the above
schedule of compliance, the permittee shall submit either a report of
progress or, in the case of specific actions being required by identified
dates, a written notice of compliance or noncompliance. In the latter case ,
the notice shall include the cause of noncompliance , any remedial actions ,
taken, and the probability of meeting the next scheduled requirement.
B-9
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Part II
Page II-l
A. MANAGEMENT REQUIREMENTS
1. Discharge Violations
All discharge* authorized herein ahall be consistent vith the terms
and conditions of this permit. The discharge of any pollutant more
frequently than, or at a level in excess of, that identified and
authorised by this permit constitutes a violation of the terms and
conditions of this permit. Such a violation may result in the
ieposition of civil and/or criminal penalties as provided in Section
309 of the Act.
2. Change in Discharge
Ar.y anticipated facility expansions, production increases, or process
modifications which will result in new, different, or increased
discharges of pollutants must be reported by submission of a new
NPDES application at least 180 days prior to commencement of such
discharge. Any other activity which would constitute cause for
modification or revocation and reissuance of'this permit, as
described in Part II (B) (4) of this permit* shall be reported to the
Permit Issuing Authority.
3. Noncompliance Notification
a. Instances of noncompliance involving toxic or hazardous pollutants
should be reported as outlined in Condition 3c. All other instances
of noncompliance should be reported as described in Condition 3b.
b. If for any reason, the permittee does not comply with or will be
unable to comply with any discharge limitation specified in the
permit, the permittee shall provide the Permit Issuing Authority
with the following information at the time when the next Discbsrge
Monitoring Report is submitted.
(1) A description of the discharge and causa of noncompliance;
(2)' The period of noncompliance, including exact dates and timet
and/or anticipated time when the discharge will return to
compliance; and
(3) Steps taken to reduce, eliminate, and prevent recurrence of
the noncooplying discharge.
B-10
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Part XI
Page II-2
e. Toxic or hazardous discharges at defined below shall be reported
by telephone within 24 hour* after permittee become* aware of the
circumstances and followed up with information °in writing as
set foi-th in Condition 3b. within 5 days, unless this requirement
is otherwise waived by the Permit Issuing Authority:
(1) Koncomplying discharges subject to any applicable toxic
pollutant effluent standard under Section 307(a) of the Act;
(2) Discharges which could constitute a threat to human health,'
welfare or the environment. These include unusual or extra-
ordinary discharges such as those which could result from
bypasses, treatment failure or objectionable substances
passing through the treatment plant. These include Section
311 pollutants or pollutants which could cause a threat to
public drinkisg water supplies.
d. Nothir.g in this permit shall be construed to relieve the permittee
from civil or criminal penaltiea for noncompliance.
Facilities Operation
All waste collection and treatment facilities shall be operated in
a manner consistent with the following:
a. The facilities shall at all times be maintained in a good
working order and operated as efficiently as possible This
includes but is not limited to effective performance based on
design facility removals, adequate funding, effective management
adequate operator staffing and training, and adequate laboratory
and process controls (including appropriate quality assurance
procedures); and
b. Any maintenance of facilities, which might necessitate unavoidable
interruption of operation and degradation of effluent quality
shall be scheduled during noncritical water quality periods and
carried out in a manner approved by the Permit Issuing Authority.
c. The permittee, in order to maintain compliance with this permit
shall control production and all discharges upon reduction, loss,
or failure of the treatment facility untii the facility is
restored or an alternative method :f treatment is provided
Adverse Impact
The permittee aha" ^aV.e all reasonable ateps to minimize any
adverse impact wafers of the United States resulting from
B-ll
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?-rt II
Page II-3
noncompliance with any effluent limitations specified in this
permit, including such accelerated or additional monitoring as
necessary to determine the nature of the noncomplying discharge.
Bypassing
"Bypassing" means the intentional diversion of untreated or partially
treated wastes to waters of the United States from any portion of a
treatment facility. Bypassing of wastewaters is prohibited unless
all of the following conditions are met:
a. The bypass is unavoidable-i.e. required to prevent loss of life,
personal injury or severe property damage;
b. There are no feasible alternatives such as use of auxiliary
treatment facilities, retention of untreated wastes, or
maintenance during normal periods of equipment down time;
c. The permittee reports (via telephone) to the Permit Issuing
Authority any unanticipated bypass within 24 hours after
becoming aware of it and follows up with written notification
in 5 days. Where the necessity of a bypass is known (or should
be known) in advance, prior notification shall be submitted to
the Permit Issuing Authority for approve! «t least 10 dsys
beforehand, if possible. All written notifications shall contain
information as required in Part II (A)(3)(b); and
d. The bypass is allowed under conditions determined to be necessary
by the Permit Issuing Authority to minimize any adverse effects.
The public shall be notified and given an opportunity to comment
on bypass incidents of significant duration to the extent
feasible.
This requirement is waived where infiltration/inflow analyses are
scheduled to be performed as part of an Environmental Protection
Agency facilities planning project.
Removed Substances
Solids, sludges, filter backlash, or other pollutants removed in
the course of treatment or control of wastewaters shall be disposed
of in a manner such as to prevent any pollutant from such materials
from entering w*t -rs of the United States.
B-12
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Part II
Page II-4
8. Power Failures
The permittee is responsible for maintaining adequate safeguards to
prevent the discharge of untreated or inadequately treated wastes
during electrical power failures either by oieans of alternate power
sources, standby generators or retention of inadequately treated
affluent. Should the treatment works not include the above
capabilities at time of permit issuance, the permittee must furnish
within six months to the Permit Issuing Authority, for approval, an
implementation schedule for their installation, or documentation
demonstrating that such measures are not necessary to prevent discharge
of untreated or inadequately treated wastes. Such documentation
•hall include frequency and duration of power failures and an eatimate
of retention capacity of untreated effluent.
9. Onshore or Offshore Construction
This permit does not authorise or approve the construction of any
onshore or offshore physical atructures or facilities or the
undertaking of any work in any waters of the United States.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the Permit Issuing Authority and/or
authorised representatives (upon presentation of credentials and
such other documents as may be required by law) to:
a. Enter upon the permittee's premises where an effluent source
is lc «ted or in which any records are required to be kept under
the terms and conditions of this permit;
b. Have access to and copy at reasonable timea any records required
to be kept under the terms and conditions of this permit;
c. Inspect at reasonable times any monitoring equipment or
monitoring method required in this permit;
d. Inspect at reasonable times any collection, treatment, pollution
management or discharge facilities required under the permit; or
e. Sample at reasonable times any discharge of pollutants.
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Part II
Page II-5
2. Transfer of Ownership or Control
A permit nay be transferred to another party under the following
conditions:
a. The permittee notifies the Permit Issuing Authority of the
proposed transfer;
b. A written agreement is submitted to the Permit Issuing Authority
containing the specific transfer date and acknowledgement that
the existing permittee is responsible for violations up to that
date and the new permittee liable thereafter.
Transfers are not effective if, within 30 days of receipt of proposal,
the Permit Issuing Authority disagrees and notifies the current
permitttee and the new permittee of the intent to modify, revoke and
reissue, or terminate the permit and to require that a new application
be filed.
3. Availability of Reports
Except for data determined to be confidential under Section 308
of the Act, (33 U.S.C. 1318) all reports prepared in accordance with
the terms of this permit shall be available for public inspection at
the offices of the State water pollution control agency and the Permit
Issuing Authority. As required by the Act, effluent data shall not
be considered confidential. Knowingly making any false statement on
any such report may result in the imposition of criminal penalties
as provided for in Section 309 of the Act (33 U.S.C. 1319).
4. Permit Modification
After notice and opportunity for a hearing, this permit may be modified,
terminated or revoked for cause (as described in 40 CFR 122.IS et seq)
including, but not limited to, the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to
disclose fully all relevant facts;
c. A change in any condition that requires either temporary
interruption or elimination of the permitted discharge; or
d. Information newly acquired by the Agency indicating the
discharge poses a threat to human health or welfare.
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Part II
Page II-6
If the permittee believe* that any past or planned activity would
be cause for modification or revocation and reissuance under
40 CFR 122.15 et seq, the permittee must report such information to
the Permit Issuing Authority. The submission of a new application
may be required of the permittee.
Toxic Pollutants
a. Notwithstanding Part II (B)(4) above, if « toxic effluent
standard or prohibition (including any schedule of compliance
specified in such effluent standard or prohibition) is established
under Section.307(a) of the Act for a toxic pollutant which is
present in the discharge authorised herein and such standard
or prohibition is more stringent than any limitation for such
pollutant in this permit, this permit shall be revoked and
reissued or modified in accordance with the toxic effluent
standard or prohibition and the permittee so notified.
b. An effluent standard established for a pollutant which is
injurious to human health is effective and enforceable by the
time set forth in the promulgated standard, even though this
permit has not as yet been modified assoutlined in Condition 5a.
Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing", Part II
(A) (6), nothing in this permit shall be construed to relieve the
permittee from civil or criminal penalties for noncompliance.
Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from
any responsibilities, liabilities, or penalties to which the
permittee is or may be aubject under Section 311 of the Act
(33 U.S.C. 1321).
State Laws
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from
any responsibilities, liabilities, or penalties established
pursuant to any applicable State law or regulation under authority
preaerved by Section 510 of the Act.
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Part II
Page II-7
9. Property Righta
The issuance of this permit does not convey any property rights in
either real or personal property• or any excluaive privileges, nor
does it authorise any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State, or local
laws or regulation*.
10. Severability
The provisions of thia permit are severable, and if any provision
of this permit, or the application of any provision of this permit
to any circumstance, ia held invalid, the application of auch
provision to other circumstances, and the remainder of this permit
shall not be affected thereby.
11. Permit Continuation
A new application shall be submitted at least 180 days before the
expiration date of this permit. Where EPA is the Permit Issuing
Authority, the terms and conditions of tfcis permit are automatically
continued in accordance vith 40 CFR 122*5, provided that the permittee
has submitted a timely and sufficient application for a renewal permit
and the Permit Issuing Authority is unable through no fault of the
permittee to issue a new permit before the expiration date.
C. MONITORING AND REPORTING
1. Representative Sampling
Samples and measurements taken as required herein shall be
repreaentative of the volume and nature of the monitored discharge.
2. Reporting
Monitoring results obtained during each calendar month shall be
summarized for each month and reported on a Discharge Monitoring
Report Form (EPA No. 3320-1). Forms shall be submitted at the end
of each calendar quarter and shall be postmarked no later than the
28th day of the aionth following the end of the quarter. The first
report ia due by the 28th day of the month following the first full
quarter after the effective date of this permit.
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Part II
Page II-8
Signed copies of these, and all other reports required herein, shall
be submitted to the Permit Issuing Authority at the following'
address(es):
address(es)
Permit Compliance Branch
Environmental Protection Agency
Region IV
345 Court.land Street, N.E.
Atlanta, Georgia 30365
Tent Procedures
Test procedures for the analysis of pollutants shall conform to all
regulations published pursuant to Section 304(h) of the Clean Water
Act, as amended (40 CFR 136, "Guidelines Establishing Test Procedures
for the Analysis of Pollutants").
Recording of Results
For each measurement or sample taken pursuant to the requirements
of this permit, the permittee shall record the following information:
a. The exact place, date, and time of sampling;
b. The person(s) who obtained the samples or measurements;
c. The dates the analyses were performed;
d. The person(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of all required analyses.
Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s)
designated herein more frequently than required by this permit,
using approved analytical methods as specified above, the results
of such monitoring shall be included in the calculation and reporting
of the values required in the Discharge Monitoring Report Foi.:i
(EPA No. 3320-1). Such increased frequency shall also be .'r.dicated.
B-17
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Part II
Page II-9
6. Records Retention
The permittee shall maintain records of all nonitoring including:
sampling dates and tines, sampling methods used, persons obtaining
samples or measurements, analyses dates and times, persons performing
analyses, and results of analyses and meaaurements. Records shall
be maintained for three years or longer if there is unresolved
litigation or if requested by the Permit Issuing Authority.
D. DEFINITIONS
1. Permit Issuing Authority
The Regional Administrator of EPA Region IV or designee.
2. Act
"Act" means the Clean Water Act (formerly referred to as the Federal
Water Pollution Control Act) Public Law 92-500, as amended by Public
Law 95-217 and Public law 95-576, 33 U.S.C. 1251 et seq.
3. Mass/Day Measurements
a. The "average monthly discharge" is defined as the total mass of
•11 daily discharges sampled and/or measured during a calendar
month on which daily discharges are sampled and measured, divided
by the number of daily discharges sampled and/or measured during
such month. It is, therefore, an arithmetic mean found by adding
the weights of the pollutant found each day of the month and then
dividing this sum by the number of days the tests were reported.
This limitation is identified as "Daily Average" or "Monthly
Average" in Part I of the permit and the average monthly discharge
value is reported in the "Average" column under "Quantity" on
the Discharge Monitoring Report (DMR).
b. The "average weekly discharge" is defined as the total mass of
all daily discharges sampled and/or measured during a calendar
week on which daily discharges are sampled and/or measured
divided by the number of 'daily discharges sampled and/or measured
during auch week. It is, therefore, an arithmetic mean found by
adding the weights of pollutants found each day of the week and
then dividing this sum by the number of days the tests were
reported. This limitation is identified as "Weekly Average" in
Part I of the permit and the average weekly discharge value is
reported in the "Maximum" column under "Quantity" on the DMR.
e. The "maximum daily discharge" is the total mass (weight) of a
pollutant discharged during a calendar day. If only one
•ample is taken during any calendar day the weight of pollutant
B-18
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Part II
P«ge 11-10
calculated from it is the "maximum daily discharge". This
limitation is identified as "Daily Mar.imum," in Part I of the
permit and the highest such value recorded during the reporting
period is reported in the "Maximum" column under "Quantity"
on the DMR.
4. Concentration Measurements
a. The "average monthly concentration," other than for fecal
coliform bacteria, is the concentration of all daily discharges
sampled and/or measured during a calendar month on which daily
discharges are sampled and measured divided by the number of
daily discharges sampled and/or measured during such month
(arithmetic mean of the daily concentration values). The daily
concentration value is equal to the concentration of a composite
sample or in the case of grab samples is the arithmetic mean
(weighted by flow value) of all the samples collected during
that calendar day. The average monthly count for fecal coliform
bacteria is the geometric mean of the counts for samples collected
during a calendar month. This limitation is identified as
"Monthly Average" or "Daily Average" under "Other Limits" in
Part I of the permit and the average monthly concentration value
is reported under the "Average" columh under "Quality" on the DMR.
b. The "average weekly concentration," other than for fecal coliform
bacteria, is the concentration of all daily discharges sampled
and/or measured during a calendar week on which daily dischargee
are sampled and measured divided by the number of daily discharges
sampled and/or measured during such week (arithmetic mean of the
daily concentration values). The daily concentration value is
equal to the concentration of a composite sample or in the case of
grab samples is the arithmetic mean (weighted by flow value) of
all samples collected during that calendar day. The average
weekly count for fecal coliform bacteria is the geometric mean
of the counts for samples collected during a calendar week. This
limitation is identified as "Weekly Average" under "Other Limits"
in Part I of the permit and the average weekly concentration
value is reported under the "Maximum" column under "Quality" on
the DMR.
c. The "maximum daily concentration" is the concentration of a
pollutant discharged during a calendar day. It is identified
as "Daily Maximum" under "Other Limits" in Part I of the permit
and the highest such value recorded during the reporting period
is reported under the "Maximum" column under "Quality" on the
DMR.
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Part II
Page 11-11
Other Measurement*
a. The effluent flow expressed as M^/day (MCD) is the 24 hour
average flow averaged monthly. It is the arithmetic mean of
the total daily flows recorded during the calendar month.
Where monitoring requirements for flow are specified in Part I
of the permit the flow rate values are reported in the "Average"
column under "Quantity" on the OMR.
b. Where monitoring requirements for pH, dissolved oxygen or fecal
coliform are specified in Part I of the permit the values are
generally reported in the "Quality or Concentration" column on
the DMR.
Types of Samples
a. Composite Sample - A "composite sample" is any of the following:
(1) Not less than four influent or effluent portions collected
at regular intervals over a period of 8 hours and fcomposited
in proportion to flow.
(2) Not less than four equal volume influent or effluent
portions collected over a period of 8 hours at intervals
proportional to the flow.
(3) An influent or effluent portion collected continuously
over a period of 24 hours at a rate proportional to the flow.
b. Grab Sample: A "grab sample" is a single influent or effluent
portion which is not a composite sample. The sample(s) shall be
collected at the period(s) most representative of the total
discharge.
Calculation of Means
a. Arithmetic Mean: The arithmetic mean of any set of values is
the summation of the individual values divided by the number
of individual values.
b. Geometric Mean: The geometric mean of any set of values is the
root of the product of the individual values where N is equal
to the number of individual values. The geometric mean is
equivalent to the antilog of the arithmetic mean of the logarithms
of the individual values. For purposes of calculating the
geometric mean, values of sero (0) shall be considered to be one U)>
B-20
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Part II
Page 11-12
c. Weighted by Flow Value: Weighted by flow value means the
•unmation of each concentration times its respective flow
divided by the stagnation of the respective flows.
8. Calendar Day
a. A calendar day is defined as the period from midnight of one
day until aidnight of the next day. However, for purposes of
this permit, any consecutive.24-hour period that reasonably
represents the calendar day may be used for sampling.
B-21
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DR
Page III-l
A Tr~' Permit No. FL0000817
JAN 11 1982
PART III
OTHER REQUIREMENTS
A. There shall be no discharge of polychlorinated blphenyl compounds such as
those commonly used for transformer fluid.
B. The company shall notify the Director, Enforcement Division, in writing not
later than sixty (60) days prior to instituting use of any additional biocide
or chemical used in condenser cooling systems, other than chlorine, which may
be toxic to aquatic life. Such notification shall Include •
1. Name and general composition of biocide or chemical
2. Quantities to be used
3. Frequencies of use
4. Proposed discharge concentrations
5. EPA registration number, if applicable
C. There shall be no discharge to waters of the United States of low volume wastes
(wastewater from all sources except those for which specific limitations are
otherwise required in this permit, including, but not limited to waste waters
from wet scrubber air pollution control systems, ion exchange water treatment
systems, water treatment evaporator blowdown, laboratory and sampling streams,
floor drainage, cooling tower basin cleaning wastes and blowdown from recir-
culating house service water system), or metal cleaning wastes (including water
wash operations).
D. If an applicable standard or limitation is promulgated under sec-
tions 301(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) and that ef-
fluent standard or limitation is more stringent than any effluent
limitation in this permit or controls a pollutant not limited in
this permit, this permit shall be promptly modified or revoked and
reissued to conform to that effluent standard or limitation.
E. The State of Florida Department of Environmental Regulation has certified the
discharge(s) covered by this permit with conditions (Attachment B). Section 401
of the Act requires that conditions of certification shall become a condition of
the permit. Hie monitoring and sampling shall be as indicated for those para-
meters included in the certification. Any effluent limits and any additional
requirements specified in the attached state certification which are more stringent,
supersede any less stringent effluent limits provided herein. During any time
period in which the more stringent state certification effluent limits are stayed
or inoperable, the effluent limits provided herein shall be in effect and fully
enforceable. (Note: Certification to be provided before permit issuance.)
B-22
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TECO Big Bend Units 1-3
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JAN 11 1982
Big Bend Station
Units 1, 2 and 3
Permit Rationale
HPDES No. FL0000817
I. Applicable Regulations
A. The proposed conditions provide for compliance with (1) Effluent
Guidelines and Standards for the steam electric power generating point
source category (40 CFR 423) as promulgated on October 8, 1974 ( 39
Federal Register 36186), and with proposed guidelines revisions
published on October 14, 1980 (45 FR 68328) for plant chemical wastes; and
(2) a tentative determination under sections 316(a) and 316(b) of the
Clean Water Act for the thermal component of the discharge and for
the plant cooling water intake, respectively; as well as,
B. Provisions of the "Florida Water Quality Standards (Chapter 17-3,
Florida Administrative Code). The receiving waters have been classi-
fied by the State of Florida as Class III - Recreation - Propagation
and Management of Fish and Wildlife - Surface wAters.
II. Effluent Limitations
A; Outfall Serial Numbers 001, 003, 004 and 005* ~ Once-through
Cooling Water
1. Temperature: A weekly average of 9.3°C(16.8°F) is included based
on the 316(a) Determination, historical data and expected future
operating levels.
2. Total residual oxidants (total residual chlorine):
Limitation of 0.20 mg/1 is based on Florida Water
Quality Standards and is more stringent than ef-
fluent guidelines^(40 CFR 423.12(b)(7)). Details
of the rationale are Included in the Environmental
Impact Statement for Big Bend 4. A detailed chlorine
minimisation study is underway to determine minimum
levels of chlorine necessary for biofouling control
and the permit requires minimisation consistent with
study results. Future limitations consistent with
proposed guidelines (423.13 (b) through (d)) are in-
cluded. Additionally, a decay study on oxidant con-
centrations in the discharge canal is required by the
permit. Subsequent to completion of these studies,
permit modification can be pursued should conditions
require further reduction in total residual oxidant
level.
3. Flow: Use of dilution pumps is prohibited (except for once per
week maintenance) consistent with the 316(b) Determination.
* Discharge serial number 005 has been redesignated ss the combined cooling water
discharge (001, 003, and 004) for limitation and monitoring purposes.
B-24
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-2-
B. Outfall Serial Number 002 - Slag Pond Discharge
1. Total suspended solids - Data submitted by the applicant has
demonstrated that total suspended solids (TSS) present in the plant
intake water are passing through the slag pond in concentrations
which exceed effluent limitations (40 CFR 423.12(b)(4) and nronn.eri
423.14(c)). Therefore, effluent limitations have been included
in the draft permit based on a "net" basis as allowed in 40 CFR
122.63(h). Additional monitoring for TSS and heavy metals Is In-
cluded In the draft permit to demonstrate continued eligibility
for and compliance with the net limitations.
Ambient levels of arsenic, cadmium, chromium, copper, Iron
mercury , nickel and selenium exceed Florida Water Quality '
Standards Criteria; therefore, the addition of any of these
parameters would technically violate the Standards. Due to
the relatively Low levels of addition, a variance to
State criteria has been granted for a two-year period.
During this period , the Permittee will be required to
evaluate additional treatment alternatives to reduce
or eliminate the discharge of suspended heavy metals.
Additional treatment technologies could Include chemi-
cal precipitation, filtration and/or recycle,, etc.
A report on this evaluation Is required by March 16 ,
1983 (18 months after granting the variance), subse-
quently determinations will be made as to requirements
for additional treatment. Information on ambient con-
ditions and variance discussions are Included In the
Environmental Impact Statement for Big Bend Unit 4.
2. Oil and grease and pH permit requirements are based on requirements
of 40 CFR 423.12(b)(1) and (4) and proposed 423.14(c) and (e).
Quantity limitations for oil and grease are based on 15 and 20 mg/1
as 30-day (daily average) and one-day (daily maximum) concentrations,
respectively. Flow is based on the application (8.21 MGD average).
The calculation is as follows: Quantity (lbs/day) * Concentration
(mg/1) x Flow(MGD) x Conversion factor, where 8.345 is the
appropriate conversion factor.
C. Outfall Serial Number 005
The application was for boiler blowdown to the slag pond; however,
historical data indicates that concentrations of iron and copper have
been significantly below requirements of 40 CFR 423.12(b)(6). A best
professional judgement has been made that future concentrations of iron
and copper should be no greater than historical values and even if
They were, the slag pond would provide adequate treatment. Additionally,
proposed 40 CFR 423.12 and 423.14 have deleted boiler blowdown as a
separate category and have included it in the low volume waste category
which is not subject to iron and copper limitations. Therefore, boiler
blowdown has been excluded from separate monitoring and this waste is
covered in requirements for OSN 006. OSN 005 has been redesignated as
previously indicated.
B-25
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Outfall Serial Number 006 - Coal Pile Runoff
Limitations are based on 40 CFR 423.42 and proposed 40 CFR 423.12(b)(9)
and (10) and 423.14(a).
Other Waste Sources: Low volume wastes and metal cleaning wastes are
discharged to onsite ponds for evaporation and percolation and/or are
spray irrigated on the plant site. Mo discharge to waters of the United
States occurs and therefore no limitations are included in the draft
permit. Fly ash is handled dry and is presently sold.
Priority Pollutant Data
Data as required by 40 CFR 122.53 (d)(7)(ii) has been submitted by the
applicant making it eligible for a five-year permit. Best professional
judgement evaluation of the data indicates that no additional treatment
is required for priority pollutants, with the possible exception of
heavy metals present in the slag pond effluent. However, a final de-
cision will be contingent on the State granting and EPA approving a
variance as Indicated in Item B. above. Should reduction of heavy
metals be necessary, treatment technology Is available to produce
acceptable effluent quality (chemical precipitation, filtration, etc.)
Proposed Permit Period: Effluent limitations have been included in the
draft permit to assure compliance with all promulgated and proposed
revisions to 40 CFR 423. Additionally, a reopener clause (Part III.D.)
has been included in the draft permit should more stringent requirements
be promulgated than are presently proposed. (Also see Item F. above.)
A five-year permit is proposed.
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Appendix C
FINAL ORDER - FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION -
VARIANCE TO STATE WATER QUALITY STANDARDS
-------
BEFORE THE STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
TAMPA ELECTRIC COMPANY,
Petitioner,
vs.
STATE OF FLORIDA, DEPARTMENT
OF ENVIRONMENTAL REGULATION,
Respondent..
Case No. 81-1463
FINAL ORDER
BY THE DEPARTMENT:
On August 5, 1981, the duly appointed hearing officer in
this case completed and submitted to the Department and all
parties a Recommended Order, consisting of Findings of Fact,
Conclusions of Law and Recommendation. A copy of the Recommended
Order is attached hereto as Exhibit "A".
Pursuant to Section 17-1.68(1), Florida Administrative Code,
and Section 120.57(l)(b)(8), Florida Statutes, parties are
allowed ten (10) days in which to submit written exceptions to the
Recommended Order. Neither party submitted exceptions. The
Recommended Order thereafter came before me, as head of the
Department, for final agency action on this matter.
Having considered the.Recommended Order, including Findings
of Fact, Conclusions of Law and Recommendation of the hearing
officer, it is therefore:
ORDERED by the ^tate of Florida, Department of Environmental
Regulation that the hearing officer's Recommended Order is hereby
adoDted in totoas the final action of this asrencv.
Further, as agreed to by Petitioner, the following effluent
limitations shall apply to the discharge from the saltwater slag
pond during the period of this variance:
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Parameter
Effluent Limitations
Arsenic 0.30 mg/l
Cadmium 0.032 mg/l
Chromium 0.24 mg/l
Copper 0.14 mg/l
Iron 3.44 mg/l
Mercury 0-1 mg/l
Nickel 0.22 mg/l
Selenium 0.32 mg/l
DONE AND ENTERED this (C day of September 1981, in
Tallahassee, Florida.
STATE OF FLORIDA DEPARTMENT
OF ENVIRONMENTAL REGULATION
Fi'.in*. ».n Kits cr.; s. y«.v.:-:n to ii'S.
Flws'ia Siv.uvs, viriili tte ('¦'.rv.nri'.i'j Depart-
ment Clerk, receipt cf v.i-.ish is heresy acknow-
ledged
9-/7-
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STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
AUG 6 I98T
Dept. of Environmental Regulatio;
Office of General Counsel
TAMPA ELECTRIC COMPANY,
Petitioner,
vs.
DEPARTMENT OF ENVIRONMENTAL
REGULATION,
Respondent.
Case No. 81-1463
RECOMMENDED ORDER
Pursuant to notice, an administrative hearing was
held before Diane D. Tremor, Hearing Officer with the Division
of Administrative Hearings, on June 23, 1981, in the Hillsborough
County Courthouse, Tampa, Florida. Tlio issue for determination
at the hearing was whether the Department of Environmental Regulation
should grant Tampa Electric Company's petition for a variance from
certain Florida water quality standards for the discharge from the
existing slag pond for Units 1, 2 and 3 of the Big Bend Generating
Station located in Hillsborough County, Florida. The parties
agreed upon all issues at or prior to the hearing and their Joint
Exhibits 1, 2 and 3 were received into evidence.
APPEARANCES
For Petitioner: Lawrence N. Curtin
Holland & Knight
Post Office Drawer BW
Lakeland, Florida 33802
For Respondent: Louis F. Hubener
Assistant General Counsel
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
FINDINGS OF FACT
Upon consideration of the petition for a variance,
the recommendation of the Department of Environmental Regulation
EXHIBIT "A"
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and the prehearing stipulation of the parties, the following
relevant facts are found:
(1) Tampa Electric Company is the owner and
operator of the Big Bend Generating Station which presently con-
sists of three coal fired steam electric generating units (Units
1, 2 and 3) in Hillsborough County, Florida. The Big Bend
Generating Station is located on the eastern shore of Hillsborough
Bay, a Class III body of water. Discharges from the Big Bend
Station are subject to regulation by the Department of Environ-
mental Regulation.
(2) The discharge that is the subject of this
proceeding is from the slag p
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(¦'.) Water quality data for the Big Bend Units 1,
2 and 3 slag pond discharge collected during the 1980-1981 study
demonstrate that there will be either minimal or no net increase,
or a reduction between the ambient intake and discharge for all
metals except iron and selenium. Upon mixing with the flow in
the discharge canal,.water quality impacts due to these parameters
are expected to be minimal.
(5) The Department of Environmental Regulation has
recommended granting a variance for the parameters cadmium, mercury
and nickel based upon the following:
(a) mercury concentrations decrease upon passing
through the slag pond;
(b) cadmium and nickel concentrations remain the
same passing throuyh the slag pond; and, therefore,
(c) the slag pond system does not appear to con-
tribute to the existing water quality violations for cadmium,
mercury, or nickel.
(6) The Department of Environmental Regulation's
analysis of the other parameters indicates that the concentrations
of arsenic, chromium, iron and selenium increase in passing through
the slag pond system. This increase appears to be due to an increase
in suspended metals.
(7) Additional treatment of the discharge from the
slag pond would be necessary to meet water quality criteria in the
effluent for the parameters arsenic, chromium, iron and selenium.
Compliance would require further removal of these parameters
possibly by the use of a reverse osmosis treatment svstem. T^e
cost of treating the slag pond discharge pond stream to comply with
water quality standards by use of reverse osmosis would be approxi-
mately $28.2 million. The $28.2 million expenditure is not justified
or practicable in this case. The Department of Environmental Regulation
C-5
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agrees that this expenditure is not justified in this case
and has recommended a variance for these parameters as well.
(8) The damage or harm resulting or which may
result to Tampa Electric Company from compliance with the rules
from which the variance relief is sought would be the expendi-
ture of $28.2 million for an additional treatment system with no
significant resulting benefit to the environment. The failure
of the Department of Environmental Regulation to grant the
requested variance could result in Tampa Electric Company being
unable to operate this facility.
(9) The Department of Environmental Regulation
recommends a two-year variance from the surface water quality
standards contained in Rules 17-3.061(2)(a) (arsenic), 17-3.061(2)
(d) (chromium), 17-3.121(9) (cadmium), 17-3.121(11) (copper),
17-3.121(16) (iron), 17-3.121(18) (mercury), 17-3.121(19) (nickel),
and 17-3.121(26) (selenium) of the Florida Administrative Code for
the discharge from the slag pond serving existing Big Bend Station
Units 1, 2 and 3. The recommendation is conditioned upon Tampa
Electric Company's agreement to monitor the metal content of the
slag pond discharge, to evaluate alternative treatment systems
and to submit a report describing treatment systems evaluated,
including costs and feasibility, within eighteen (18) months of
the effective date of the variance relief. Tampa Electric Company
has agreed to the recommendation and conditions of the Department
of Environmental Regulation.
(10) Appropriate public notice of this proceeding -has
been giver. At the conclusion of the hearing, th« public was
given an opportunity to comment and present evidence on the
petition for variance. No public testimony was offered.
CONCLUSIONS OF LAW
Within its discretion, the Department of Environmental
Regulation may grant a variance from its rules relating to water
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quality for any of the following reasons:
(a) There is no practicable means known or
available for the adequate control of the
pollution involved.
(b) Compliance with the particular require-
ment or requirements from which a variance
is sought will necessitate the taking of mea-
sures which, because of their extent or cost,
must be-spread over a considerable period of
time. A variance granted for this reason shall
prescribe a timetable for the taking of the
measures required.
(c) . To relieve or prevent hardship of a kind
othtfr than those provided for in paragraphs
(a) and
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Tampa Electric Company has withdrawn its requests
for variances from the rules relating to minimum criteria,
general prohibition and lead.
RECOMMENDATION
Based upon the findings of fact and conclusions
of law recited herein, it is RECOMMENDED that Tampa Electric
Company be granted a two-year variance from the surface water
quality standards contained in Rules 17-3.061(2)(a) (arsenic),
17-3.061(2)(d) (chromium), 17-3.121(9) (cadmium), 17-3.121(11)
(copper), 17-3.121(16) (iron), 17-3.121(18) (mercury), 17-3.121(19)
(nickel) and 17-3.121(26) (selenium), Florida Administrative Code,
for discharges from the slag pond for existing Big Bend Station
Units 1, 2 and 3. The granting of this variance should be con-
ditioned upon Tampa Electric Company's agreement to monitor the
metal content of the slag pond discharge during the duration of
the variance, evaluate alternative suspended metals removal treat-
ment systems, and submit a report to the Department of Environmental
Regulation describing the treatment systems evaluated and the costs
and feasibility of those systems within eighteen (18) months of
th« effective date of the variance.
Respectfully submitted and entered this
August, 1981, in Tallahassee, Florida.
Hearing Officer
"ivioic-. jf j.nLu.'.;.ia Beamings
The Oakland Building
2009* Apalachee Parkway
Tallahassee, Florida 32301
(904) 488-9675
Copies furnished:
See attached page
Filed with the Clerk of the Division
of Administrative Hearings this ^77
day of August, 1981.
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Copies furnished:
Lawrence N. Curtin, Esquire
Holland and Knight
Post Office Drawer BW
Lakeland, Florida 33802
Louis F. Hubener, Esquire
Assistant General Counsel
Department of Environmental
Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
Hamilton S. Oven, Jr.
Administrator, Power Plant Siting
Department of Environmental
Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
Honorable Victoria Tschinkel
Secretary, Department Of
Environmental Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
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