Cost Calculations for Industrial Dischargers

November 2012

U.S. Environmental Protection Agency

Office of Water

Engineering and Analysis Division

1200 Pennsylvania Avenue N.W.

Washington, D.C. 20460
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Table of Contents

Table of Contents ........................................................................................................................................ 2

Table of Exhibits ......................................................................................................................................... 4

Acronyms..................................................................................................................................................... 6

Industrial Discharger Analyses.................................................................................................................. 7

Chemical and Allied Products ...................................................................................................................... 8

Trademark Nitrogen Corporation ....................................................................................................... 8

Electrical Services....................................................................................................................................... 10

Florida Power and Light, Indian River Plant.................................................................................... 10

Florida Power and Light, Fort Lauderdale Plant .............................................................................. 12

Florida Power and Light, Riviera Beach Energy Center .................................................................. 14

Florida Power and Light, St. Lucie Power Plant .............................................................................. 15

Gulf Power Company, Lansing Smith Power Plant ......................................................................... 16

Progress Energy Florida, Anclote Plant ........................................................................................... 19

Progress Energy Florida, Crystal River Plant Units 1, 2, and 3 ....................................................... 21

Progress Energy Florida, Crystal River Plant Units 4 and 5 ............................................................ 24

Vero Beach Municipal Power Plant ................................................................................................. 26

Food .......................................................................................................................................................... 28

Tropicana Manufacturing Company, Inc.......................................................................................... 28

Anheuser Busch Inc., Main Street Sod Farm ................................................................................... 29

Pulp and Paper ............................................................................................................................................ 31

Rayonier Performance Fibers, LLC.................................................................................................. 31

Smurfit Stone, Fernandina Beach Containerboard Mill ................................................................... 33

Smurfit Stone, Seminole Mill........................................................................................................... 35

Other .......................................................................................................................................................... 37

BP Products North America, Port Everglades North and South Terminal....................................... 37

Chevron Products Company, Panama City Terminal....................................................................... 38

Chevron Products Company, Port Everglades Terminal.................................................................. 39

Coastal Terminals LLC, Port Everglades Terminal ......................................................................... 40

CSXT Moncrief Rail Yard and Fruit Growers Express Yard........................................................... 41

ExxonMobil Oil Corporation, Port Everglades North and South Terminals.................................... 42

Florida Atlantic University Sea Tech Facility.................................................................................. 44

Harbor Branch Oceanographic Institute at Florida Atlantic University........................................... 45

Marathon Petroleum Company, Port Everglades Eisenhower Boulevard Terminal ........................ 47

Marathon Petroleum Company, Port Everglades Spangler Boulevard Terminal............................. 48

Marine Park of Flagler...................................................................................................................... 50
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Motiva Enterprises LLC, Port Everglades East Terminal ................................................................ 52

Motiva Enterprises LLC, Port Everglades South Terminal.............................................................. 53

TPSI Terminals LLC, Port Everglades Bulk Terminal .................................................................... 54

References.................................................................................................................................................. 55

Appendix: Alternative Treatment Scenario ........................................................................................... 57
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Table of Exhibits

Exhibit 1: Effluent Data Summary, Trademark Nitrogen Corporation.........................................................8

Exhibit 2: Reasonable Potential Analysis, Trademark Nitrogen Corporation ..............................................9

Exhibit 3: Effluent Data Summary, Florida Power and Light, Indian River Plant .....................................11

Exhibit 4: Effluent Data Summary, Florida Power and Light, Fort Lauderdale Plant................................13

Exhibit 5: Effluent Data Summary, Florida Power and Light, St. Lucie Plant...........................................15

Exhibit 6: Effluent Data Summary, Gulf Power Company, Lansing Smith Power Plant...........................17

Exhibit 7: Reasonable Potential Analysis, Gulf Power Company, Lansing Smith Power Plant ................17

Exhibit 8: Potential Incremental Costs, Gulf Power Company, Lansing Smith Power Plant.....................18

Exhibit 9: Effluent Data Summary, Progress Energy Florida, Anclote Plant.............................................19

Exhibit 10: Reasonable Potential Analysis, Progress Energy Florida, Anclote Plant.................................20

Exhibit 11: Effluent Data Summary, Progress Energy Florida, Crystal River Plant Units 1, 2 and 3........22

Exhibit 12: Reasonable Potential Analysis, Progress Energy Florida, Crystal River Plant Units 1, 2 and 3

............................................................................................................................................................22

Exhibit 13: Potential Incremental Costs, Progress Energy Florida, Crystal River Plant Units 1, 2 and 3..23

Exhibit 14: Effluent Data Summary, Progress Energy Florida, Crystal River Plant Units 4 and 5............24

Exhibit 15: Reasonable Potential Analysis, Progress Energy Florida, Crystal River Plant Units 3 and 4 .25

Exhibit 16: Effluent Data Summary, Vero Beach Municipal Power Plant.................................................26

Exhibit 17: Reasonable Potential Analysis, Vero Beach Municipal Power Plant ......................................27

Exhibit 18: Effluent Data Summary, Anheuser Busch Inc., Main Street Sod Farm...................................29

Exhibit 19: Reasonable Potential Analysis, Anheuser Busch Inc., Main Street Sod Farm.........................30

Exhibit 20 : Potential Incremental Costs, Anheuser Busch Inc., Main Street Sod Farm............................30

Exhibit 21: Effluent Data Summary, Rayonier Performance Fibers, LLC .................................................31

Exhibit 22: Reasonable Potential Analysis, Rayonier Performance Fibers, LLC.......................................32

Exhibit 23: Potential Incremental Costs, Rayonier Performance Fibers, LLC ...........................................32

Exhibit 24: Effluent Data Summary, Smurfit Stone, Fernandina Beach Containerboard Mill...................33

Exhibit 25: Reasonable Potential Analysis, Smurfit Stone, Fernandina Beach Containerboard Mill ........34

Exhibit 26: Potential Incremental Costs, Smurfit Stone, Fernandina Beach Containerboard Mill.............34

Exhibit 27: Effluent Data Summary, Smurfit Stone, Seminole Mill ..........................................................35

Exhibit 28: Reasonable Potential Analysis, Smurfit Stone, Seminole Mill................................................36

Exhibit 29: Potential Incremental Costs, Smurfit Stone – Seminole Mill ..................................................36

Exhibit 30: Effluent Data Summary, Harbor Branch Oceanographic Institute at FAU..............................45

Exhibit 31: Reasonable Potential Analysis, Harbor Branch Oceanographic Institute at FAU ...................46
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Exhibit 32: Potential Incremental Costs, Harbor Branch Oceanographic Institute at FAU........................46

Exhibit 33: Effluent Data Summary, Marathon Petroleum Company, Port Everglades Spangler Boulevard

Terminal..............................................................................................................................................48

Exhibit 34: Effluent Data Summary, Marine Park of Flagler .....................................................................50

Exhibit 35: Reasonable Potential Analysis, Marine Park of Flagler...........................................................51

Exhibit 36: Estimated Potential Cost of Reverse Osmosis to Meet Extremely Low Nutrient Effluent

Limits..................................................................................................................................................57
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Acronyms

BMAP – Basin Management Action Plan

BNR – Biological Nutrient Removal

FDEP – Florida Department of Environmental Protection

ICIS-NPDES – Integrated Compliance Information System for the National Pollutant Elimination

Database System

IWR – Impaired Waters Rule

Lbs – Pounds

Lbs/yr – Pounds per Year

MGD – Million Gallons per Day

Mg/L – Micrograms per Liter

RO – Reverse Osmosis

SIC – Standard Industrial Classification

SSAC – Site Specific Alternative Criteria

TMDL – Total Maximum Daily Load

TN – Total Nitrogen

TP – Total Phosphorus

U.S. EPA - U.S. Environmental Protection Agency

WLA – Waste Load Allocation
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Industrial Discharger Analyses

The U.S. Environmental Protection Agency (EPA) is proposing numeric nutrient criteria applicable to

estuaries, coastal waters, and South Florida inland flowing waters in the State of Florida. The proposed

criteria will supplement the state’s existing narrative nutrient criterion. Although the proposed rule does

not establish any requirements directly applicable to regulated entities or other sources of nutrient

pollution, EPA developed an economic analysis to provide information on potential costs and benefits

that may be associated with state implementation requirements that may be necessary to assure attainment

of water quality standards (WQS).

The potential costs associated with state implementation may include costs to control discharges of

nutrients from industrial facilities to waters covered under the proposed rule. EPA’s method for

estimating potential costs in this sector is described in the economic analysis (see Economic Analysis of

Proposed Water Quality Standards for the State of Florida’s Estuaries, Coastal Waters, and South Florida

Inland Flowing Waters in the docket for the proposed rulemaking). This document provides supporting

information for EPA’s analysis of incremental costs for the industrial sector.
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Chemical and Allied Products

Trademark Nitrogen Corporation

NPDES permit number: FL0000647

Major/minor: Minor

SIC code: 2873 (Nitrogenous Fertilizers)

Industrial Category: Chemicals and Allied Products

Design Flow: Not reported

Average Flow: 0.11 mgd (average of monthly maximum flows from 2006 - 2010)

Receiving Water: Unnamed ditch to Palm River to McKay Bay

Description

Trademark Nitrogen Corporation is a fertilizer production plant, consisting of a 125 ton per day nitric acid

plant, a 150 ton per day ammonium nitrate plant, a fertilizer solution plant, a magnesium nitrate plant, a

nitrogen-phosphorus-potassium blend plant (liquid fertilizer), and a small boiler plant. Wastewater

consists of boiler blowdown, boiler water softener backwash, cooling tower blowdown, once-through

noncontact cooling water, and stormwater runoff. All wastewater except the cooling water is treated in an

unlined, hyacinths vegetated detention ditch, which discharges through Outfall D-001 to Palm River,

thence McKay Bay. The ditch system provides for uptake of nutrients and settling of solids. Noncontact

cooling water is piped directly to a basin downstream of the vegetated ditch.

Summary of Effluent Data and Limits

Exhibit 1 summarizes average monthly effluent data for TN from 2006 to 2010. TP data are not available

from EPA’s ICIS-NPDES database, however, a laboratory report indicates that in 2008, TP

concentrations were approximately 0.048 mg/L (FDEP, 2008d). There are no effluent limits for TP in the

current permit.

Exhibit 1: Effluent Data Summary, Trademark Nitrogen Corporation

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Current Effluent Limit

(mg/L)2

Outfall D-001

TN 60 0.76 3.0

TP 1 0.048 None

Source: EPA (2011) and FDEP (2008d).

1. TN effluent data from 2006 through 2010. Represents average of maximum monthly values. TP data from 2008

laboratory report.

2. Represents monthly average limit; permit also contains a daily maximum limit of 5.0 mg/L. In addition, the 5-year

rolling average for TN may not exceed 200 lbs/yr.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.49 mg/L and 0.175 mg/L,

respectively, for McKay Bay (Segment ID 0901) of the Tampa Bay Estuary.

The Trademark Nitrogen Corporation is already covered under the McKay Bay TMDL, and has a WLA

for TN of 3.0 mg/L, which it is currently meeting. Therefore, EPA assumes that the TMDL TN targets

would be adopted as site-specific alternate criteria (SSAC), and that TN effluent limits would not be

revised as a result of the proposed rule.
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Analysis of water quality data for TP indicates that the McKay Bay segment is exceeding EPA’s proposed

annual geometric mean criterion of 0.175 mg/L. Given a lack of assimilative capacity the discharger is not

likely to receive dilution. Exhibit 2 summarizes the RP analysis and estimated projected effluent limits

for the facility.

Exhibit 2: Reasonable Potential Analysis, Trademark Nitrogen Corporation

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

TP 0.048 0.28 0.175 No

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

The exhibit indicates that the facility would not likely have RP under the proposed rule because the

average effluent concentration is below the proposed criterion. Thus, EPA assumes that an incremental

level of control would not be necessary for compliance with revised effluent limits under the proposed

rule and costs would be zero.
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Electrical Services

Florida Power and Light, Indian River Plant

NPDES permit number: FL0001538

Major/minor: Major

SIC code: 4911 (Electrical Services)

Industrial Category: Electrical Services

Design Flow: 1, 348 mgd for Outfall D-001

Average Flow: 0.22 mgd for Outfall D-0B3; 0.12 mgd for Outfall I-012; 309 mgd for

Outfall I-113; 326 mgd for Outfall I-114 (average of maximum monthly

values from 2006 through 2011)

Receiving Water: Intracoastal Waterways

Description

Florida Power and Light, Indian River Plant is an electrical generating plant consisting of four natural gas

and oil powered units with a total production capacity of 1,254 MW. The plant generates various forms of

wastewater including once-through cooling water, sluice water, economizer hopper wash, air preheater

wash, dust collector wash, equipment wash, boiler fireside wash, stack wash and water treatment effluent

streams. The low volume wastewater treatment system consists of a solids settling basin, a precipitation

basin, and a percolation basin. The solids settling and precipitation basin are lined with an impermeable

liner, while the percolation basin has a limestone bottom (for enhanced precipitation of some dissolved

metals). The water treatment system consists of multimedia filters, carbon filters, softener, RO, and

mixed bed demineralizers.

Florida Power and Light, Lauderdale Plant discharges once-through condenser cooling water, which may

be intermittently chlorinated for biofouling control, through Internal Outfalls I-111, I-112, I-113, and I114 and once-through auxiliary cooling water through Internal Outfalls I-181, I-182, I-183, and I-184

discharge. However, during periods of reserve shut down or periods of circulating water pump

malfunction, the facility may divert a portion of the auxiliary cooling water through the main condensers

and discharges it through Internal Outfalls I-1D1, I-1D2, I-1D3, and I-ID4. Outfall D-001 serves as the

common point of discharge for the condenser cooling water and auxiliary cooling water. Outfall D-001

discharges effluent to a discharge canal that ultimately discharges into the Intracoastal Waterway. This

discharge canal also receives effluent from other NPDES permitted dischargers in the Port Everglades

area.

Boiler blowdown is normally routed to the boiler blowdown recovery basin for reuse. Boiler blowdown

may also be routed to the solids settling basin or discharged directly to the intake canal through Internal

Outfall I-016.

Water treatment system effluent streams (including dust collector sluice water, economizer hopper wash,

air preheater wash, equipment wash, dust collector wash, boiler fireside wash, stack wash, boiler chemical

cleaning rinse water, carbon filter backwash, softener regeneration, and RO reject) are discharged either

to the solids settling basins and their respective overflow areas or directly to the intake canal through

Internal Outfall I-012.

The equipment area runoff treatment system collects the first inch of rainfall plus minimal flows from the

service water rinses in the power block area. Drainage from oil contaminated areas passes through oilwater separators or oil traps. Runoff in excess of the first inch is routed directly to the discharge canal via
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Internal Outfall I-1B1. Stormwater from the diked tank farm areas discharges to the intake canal via

Internal Outfall D-1B2 (North Tank Farm) or the plant discharge canal via Outfall D-0B3 (East Tank

Farm). Intake screen wash water discharges through Outfall D-019.

Summary of Effluent Data and Limits

TN and TP data are not available from EPA’s ICIS-NPDES database. However, a laboratory report

indicates that in 2008, TN concentrations were approximately 0.41 mg/L and there was no detection for

phosphorous (FDEP, 2008c) for Outfall D-001. There are no effluent limits for TN and TP in the current

permit. Exhibit 3 summarizes these data.

Exhibit 3: Effluent Data Summary, Florida Power and Light, Indian River Plant

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Existing Effluent Limit

(mg/L)

Outfall D-001

TN 1 0.41 None

TP 1 <0.02 None

Source: FDEP (2008c)

1. Data from 2008 laboratory report.

Potential Incremental Impacts

Florida Power and Light, Indian River Plant discharges to coastal waters, for which EPA is proposing

only chlorophyll-a criterion. While there are no TN and TP criteria, EPA assumes that Florida Power and

Light, Lauderdale Plant would be required to meet the concentrations associated with economically

feasible treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the

chlorophyll-a criterion.

Given the lack of permit requirements, the nature of the wastewater (e.g., mainly once-through cooling

water), and the low TN concentrations in 2008, incremental controls and costs under the proposed rule are

unlikely.
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Florida Power and Light, Fort Lauderdale Plant

NPDES permit number: FL0001503

Major/minor: Major

SIC code: 4911 (Electrical Services)

Industrial Category: Electrical Services

Design Flow: Not reported

Average Flow: 359 mgd for Outfall D-001 (average of maximum monthly values from

2006 through 2011)

Receiving Water: South Fork of New River and Dania Cutoff Canal

Description

Florida Power and Light, Lauderdale Plant is an electrical generating plant consisting of two natural gas

and oil powered units with a winter net capacity of 960 megawatts. Wastewater from this facility includes

once-through cooling water, boiler blowdown, RO concentrate, metal cleaning wastes and pretreated oily

wastewater.

Florida Power and Light, Lauderdale Plant discharges the majority of its effluent to an onsite canal

flowing into a once-through cooling pond. Effluent from the cooling pond is discharged through Outfall

D-001 to the South Fork of New River, which is a Class III marine surface water connected to coastal

waters. However, stormwater runoff from the equipment area stormwater and intake screen washwater

and strainer backwash water are discharged through Outfalls D-0B1 and D-009, respectively, to the Dania

Cutoff Canal, located immediately south of the facility. Once-through condenser cooling water is

discharged to the onsite canal and then the cooling pond via Internal Outfalls I-011A and I-011B.

The process water treatment system provides treated water from onsite wells for combustion turbine

steam injection, heat recovery steam generator (HRSG) makeup, pump seal water, evaporative coolers,

and HRSG chemical cleaning. Activated carbon pressure filters treat the source water to remove organic

materials and suspended solids before removal of dissolved solids in the RO units. After RO treatment,

the water flows through a de-gasifier to remove carbon dioxide followed by a mix-bed demineralizer for

final polishing. The facility neutralizes RO concentrate and demineralizer regeneration wastewater from

the processes water treatment system prior to discharge through Internal Outfalls I-01E and I-012,

respectively, to the onsite canal and thence the cooling pond.

Oily stormwater runoff is collected from the transformer area runoff and fuel oil storage, and diverted to

the oily wastewater surge basin, where a separator removes free oils/grease. If required, the water passes

through dissolved air flotation separation to remove emulsified oils. The treated effluent is combined with

other non-oily wastewaters, which include HRSG blowdown and chemical cleaning rinse. The combined

wastewaters are treated by the facility’s wastewater treatment system, consisting of a wastewater

equalization basin, package clarifier (a flash/floc mix tank and settling compartment plus chemical

addition, if necessary), three parallel duel medial gravity filters, and pH adjustment tanks. The facility

discharges the treated wastewaters through Outfall I-013 to the onsite canal and thence the cooling pond.

HRSG blowdown is routed to a flash tank where much of the water flashes to steam and the remaining

boiler blowdown is treated by the wastewater treatment system. During various maintenance activities,

HRSG blowdown may bypass the wastewater treatment system for direct discharge to the onsite canal

through Internal Outfalls I-016A and I-016B.

The infrequent cleaning of the HRSG to remove corrosion and scale (once every 3 to 5 years for each

unit) generates HRSG chemical cleaning rinse wastewaters. These wastewaters are batch treated in the
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wastewater treatment system separately from other wastewaters. Due to the large volume of wastewater

associated with each cleaning event (approximately 500,000 gallons), a separate lined equalization basin

is used to collect this wastewater prior to the treatment. Treated HRSG chemical cleaning rinse water is

discharged through Internal Outfall I-015 to the onsite canal and thence the cooling pond.

Stormwater runoff from the equipment area discharges through either Outfall D-0B1 to the Dania Cutoff

Canal or Internal Outfall I-1B2 to the onsite canal and thence the cooling pond. Stormwater runoff from

other areas discharges to the cooling canal and then the cooling pond through Internal Outfall I-1B3.

Temporary dewatering activities may be required during below ground construction (no description of

construction activities is provided by the facility permit) and release water will be discharged through

Internal Outfall I-01D to the onsite canal and thence the cooling pond.

Summary of Effluent Data and Limits

TN and TP data are not available from EPA’s ICIS-NPDES database. However, a laboratory report

indicates that in 2008, TN concentrations were approximately 1.22 mg/L and TP concentrations were

approximately 0.026 mg/L (FDEP, 2008b) for Outfall D-001. There are no effluent limits for TN and TP

in the current permit. Exhibit 4 summarizes these data.

Exhibit 4: Effluent Data Summary, Florida Power and Light, Fort Lauderdale Plant

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Existing Effluent Limit

(mg/L)

Outfall D-001

TN 1 1.22 None

TP 1 0.026 None

Source: FDEP (2008b)

1. Data from 2008 laboratory report.

Potential Incremental Impacts

Florida Power and Light, Fort Lauderdale Plant discharges to coastal waters, for which EPA has proposed

only chlorophyll-a criterion. While there are no TN and TP criteria, EPA assumes that the Florida Power

and Light would be required to meet the concentrations associated with economically feasible treatment

(i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the chlorophyll-a

criterion. Thus, based on available effluent data, incremental controls and costs under the proposed rule

are unlikely.
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Florida Power and Light, Riviera Beach Energy Center

NPDES permit number: FL0001546

Major/minor: Major

SIC code: 4911 (Electrical Services)

Industrial Category: Electrical Services

Design Flow: 599 mgd

Average Flow: Not reported

Receiving Water: Lake Worth to the Intracoastal Waterways

Description

Florida Power and Light, Riviera Beach Energy Center is an electric generating plant that recently ceased

operations in preparation for the construction of the company’s Riviera Beach Next Generation Clean

Energy Center (a large modernization project which will begin serving customers in 2014). The new,

high-efficiency, combined-cycle natural gas turbines (1,250 megawatt in total capacity)1 Unit 5 includes

three gas turbines which will burn a variable combination of natural gas and No. 2 ultralow sulfur

distillate fuel oil as a backup. The new equipment will have condenser once-through cooling water and

auxiliary equipment cooling water systems that use water from Lake Worth Lagoon (a coastal marine

waterbody). Auxiliary equipment cooling water and other wastewater streams will combine with the

once-through cooling water for treatment by chlorination, followed by dechlorination prior to discharge

through Outfall D-013 to Lake Worth, which ultimately discharges to the Intracoastal Waterway.

Metal cleaning wastewater and RO membrane cleaning wastewater will be disposed of offsite. Other

wastewater including washdown from cleaning and maintenance activities (which will be routed through

an oil/water separator); RO reject; softener; multimedia filter backwash; low-volume and metal cleaning

wastewater; and combined blowdown (from the Heat Recovery Steam Generators and Evaporative

Coolers) will all ultimately discharge through internal outfalls to Outfall D-013 as well. When possible,

some of the blowdown wastewaters will be reused as make-up water to the onsite water treatment system.

Equipment area stormwater will be routed through an oil/water separator and then to a series of onsite

retention ponds before discharge. All surface water will discharge to the Intracoastal Waterway (through

Outfalls D-009, D-012, and D-013).

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this facility.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.55 mg/L and 0.067 mg/L,

respectively, for the North Lake Worth Lagoon segment (Segment ID 1201).

Florida Power and Light, Riviera Beach Energy Center is not currently discharging due to construction,

and is not scheduled to resume operations until 2014. In addition, given the lack of permit requirements

and the nature of the wastewater (e.g., mainly once-through cooling water), RP and revised effluent limits

for TN or TP under the proposed rule are unlikely even once the facility opens. Thus, incremental

compliance costs are likely minimal.

1

http://www.fpl.com/environment/plant/riviera.shtml
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Florida Power and Light, St. Lucie Power Plant

NPDES permit number: FL0002208

Major/minor: Major

SIC code: 4911 (Electrical Services)

Industrial Category: Electrical Services

Design Flow: 1,478 mgd

Average Flow: 1,386 mgd (average of maximum monthly values from 2006 through

2011)

Receiving Water: Atlantic Ocean

Description

Florida Power and Light, St. Lucie Power Plant is a power plant with two nuclear powered steam electric

generating units with a combined capacity of 1,700 megawatts. The facility discharges noncontact oncethrough condenser cooling water and auxiliary equipment cooling water, which are treated by

chlorination. Low volume wastes (including water treatment system wastewater, steam generator/boiler

blowdown, and equipment area floor drainage), non-radioactive wastes/liquid radiation waste, and

industrial stormwater are treated by chemical/physical processes including neutralization, settling, ion

exchange and microfiltration. Stormwater and intake screen washwater are discharged without treatment.

All surface water effluent is discharged to the Atlantic Ocean via onsite drainage canals through Outfall

D-001.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

However, laboratory reports indicate that in 2010, TN concentrations were approximately 0.356 mg/L and

TP concentrations were approximately 0.021 mg/L for Outfall D-001 (FDEP, 2010a). There are no

effluent limits for TN and TP in the current permit. Exhibit 5 summarizes these data.

Exhibit 5: Effluent Data Summary, Florida Power and Light, St. Lucie Plant

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Existing Effluent Limit

(mg/L)

Outfall D-001

TN 1 0.356 None

TP 1 0.021 None

Source: FDEP (2010a)

1. Data from 2010 laboratory report.

Potential Incremental Impacts

EPA is proposing a chlorophyll-a criterion for coastal waters. While there are no TN and TP criteria, EPA

assumes that the Florida Power and Light, St. Lucie Power Plant would be required to meet the

concentrations associated with economically feasible treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP)

to reduce the potential for exceeding the chlorophyll-a criterion. Thus, based on available effluent data,

incremental controls and costs under the proposed rule are unlikely.
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Gulf Power Company, Lansing Smith Power Plant

NPDES permit number: FL0002267

Major/minor: Major

SIC code: 4911 (Electrical Services)

Industrial Category: Electrical Services

Design Flow: 273.6 mgd for Outfall D-001

Average Flow: Not reported

Receiving Water: Warren Bayou and Alligator Bayou

Description

Gulf Power Company, Lansing Smith Power Plant is an electric generating plant with a total rating of 924

megawatts. The facility includes two fossil fuel-fired steam generators (Units 1 and 2), two gas-fired

combined cycle combustion turbine electrical generators each with a duct-fired heat recovery steam

generator (Unit 3), and two combustion turbines. Units 1 and 2 utilize a primary fuel of pulverized coal

with a distillate fuel oil back-up. Units 1 and 2 use once-through cooling water while Unit 3 uses a closed

loop steam condenser cooling system cooling tower.

Wastewater streams discharged to the onsite discharge canal include once-through cooling water from

Units 1 and 2, cooling tower blowdown from a closed loop cooling system for Unit 3 through Internal

Outfall I-017, ash pond overflow, and evaporative cooler blowdown and clean drain effluent from the

turbine/boiler building. Collected stormwater is drained and released to the site runoff water system

through transformer enclosure drains. The onsite discharge canal discharges through Outfall D-001 to the

Warren Bayou.

Numerous other wastewaters are discharged to the ash pond including include treated metal cleaning

waste through Outfall I-015, treated domestic wastewater through Outfall I-01A, boiler blowdown, water

treatment filter backwash, air preheater wash, ash and pyrite sluice, coal pile runoff, yard runoff, treated

demineralizer regeneration waste, and other minor process and non-process waste streams. Demineralizer

regeneration waste and metal cleaning waste are both neutralized and allowed to settle in a retention pond

prior to discharge to the ash pond. As a secondary treatment, domestic wastewater is sent to an extended

aeration package treatment plant prior to onsite recycling at the ash pond.

Certain types of demineralizer waste (green sand filter backwash, multimedia filter backwash, and RO

concentrate) are routed to a stormwater sump prior to discharge to the ash pond. Gas turbine and

equipment wastes pass through an oil-water separator; the wastewater drains to the site wastewater sump

prior to discharge to the ash pond. Ash pond overflow is continuously discharged through Internal Outfall

I-01C to the onsite discharge canal. Emergency ash pond overflow may be discharged through Outfall D00D to the onsite intake canal in the Alligator Bayou.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

However, a laboratory report indicates that in 2011, TN concentrations were approximately 0.253 mg/L

and TP concentrations were approximately 0.17 mg/L for Outfall D-001 (FDEP, 2011a). There are no

effluent limits for TN and TP in the current permit. Exhibit 6 summarizes these data.
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Exhibit 6: Effluent Data Summary, Gulf Power Company, Lansing Smith Power Plant

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Existing Effluent Limit

(mg/L)

Outfall D-001

TN 1 0.253 None

TP 1 0.17 None

Source: FDEP (2011a)

1. Data from 2011 laboratory report.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.22 mg/L and 0.014 mg/L,

respectively, for the Warren Bayou and Alligator Bayou in the North Bay segment (Segment ID 0407) of

the St. Andrews Bay estuary system.

Analysis of a single year of data (2008) from FDEP’s IWR database indicates that TN concentrations in

the segment are above the proposed criterion and TP concentrations are below the proposed criterion.

However, because the data are limited and no mixing zones are described in the permit, EPA

conservatively (i.e., erring on the side of estimating greater impact and higher costs under the proposed

rule) assumes no dilution is available.

Error! Reference source not found. summarizes the RP analysis and estimated projected effluent limits for

the facility.

Exhibit 7: Reasonable Potential Analysis, Gulf Power Company, Lansing Smith Power Plant

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

TN 0.253 0.449 0.22 Yes 0.22

TP 0.17 0.010 0.014 Yes 0.014

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because the ambient data are limited and the existing permit does not provide

dilution for effluent limits.

The exhibit indicates that the facility would likely have RP under the proposed rule for both TN and TP

because the average effluent concentrations exceed the proposed criteria. Based on average effluent

concentrations, the facility would not be in compliance with the projected effluent limit for TN or TP and

may need to implement some incremental level of control. However, due to the extremely low TN and TP

criteria, there is significant uncertainty as to whether the projected effluent limits are feasible to attain.

Thus, EPA estimates costs based on the assumption of a variance from meeting effluent limits based on

criteria end-of-pipe.

While existing TN concentrations are already relatively low, additional reductions in TP could be

achieved through cost-effective treatment controls. Thus, EPA estimates incremental compliance costs

based on installation of chemical precipitation followed by filtration as a condition of the variance (i.e.,

lowest levels feasible).

Capital and O&M unit costs associated with this treatment could be $0.32/gpd and $238/MG,

respectively. EPA assumes that treatment would be required only for internal outfalls likely to contain

nutrients, specifically the ash pond overflow (internal Outfall I-01C) and domestic wastewater treatment
18

effluent (internal Outfall I-01A), and not for the other wastewater components (e.g., once-through cooling

water). The facility’s permit specifies a design flow of 0.0075 mgd for internal Outfall I-O1A, but does

not report design flows from which to estimate total capital costs for internal Outfall I-01C. Therefore, to

estimate capital costs, EPA uses the 90th percentile maximum monthly flow from 2006 through 2011 to

approximate the necessary design flow (5.01 mgd for internal Outfall I-01C). Based on these flows

(approximated to be 5.01 mgd), total capital costs could be approximately $1.6 million.

During the last 5 years, average maximum monthly flows have been approximately 4.36 mgd for internal

Outfall I-01C and are assumed to equal the design flow for internal Outfall I-01A (0.0075 mgd). Thus,

based on these flows (approximated to be 4.36 mgd) and assuming operation of the treatment units 365

days per year, O&M costs could be approximately $0.38 million. Total annual costs would be $0.53

million based on annualizing capital costs at 7% over 20 years and adding annual O&M. Exhibit 8

summarizes these costs.

Exhibit 8: Potential Incremental Costs, Gulf Power Company, Lansing Smith Power Plant

Treatment Controls Capital Costs

($ million)1

O&M Cost

($ million/year)2

Annual Costs

($ million/year)3

Chemical precipitation

with filtration $1.6 $0.38 $0.53

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of

operating days per year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
19

Progress Energy Florida, Anclote Plant

NPDES permit number: FL0002992

Major/minor: Major

SIC code: 4911 (Electrical Services)

Industrial Category: Electrical Services

Design Flow: 821.7 mgd for Outfall D-004

Average Flow: Not reported for D-004; 1,083 mgd for I-001; 607 mgd for I-003; 0.18

mgd for I-006 (average of average value from 2006 through 2011)

Receiving Water: Anclote Sound

Description

Progress Energy Florida, Anclote Plant is an electric generating station with a two oil-fired steam units

with a total capacity rating of 1,112 megawatts. The facility receives once-through cooling water from an

onsite canal connected to the Anclote Sound. Once-through cooling water is discharged to the plant’s

onsite discharge canal without treatment through Internal Outfalls I-001 and I-002. During certain times

of the year, the cooling water may be sent to two non-recirculating cooling towers to reduce plant

discharge temperature in which case the water used in cooling towers is treated with a biocide and then

dehalogenated before discharge.

An additional stream used for temperature dilution may be discharged to the discharge canal through

Internal Outfall I-003. Cooling tower blowdown may be discharged to the discharge canal through

Internal Outfall I-005. The combined wastewater is returned to the Anclote Sound via through the

discharge canal via External Outfall D-004. Stormwater may be discharged to the intake canal from

Internal Outfall I-006. All other wastewater treatment is discharged into two onsite

percolation/evaporation ponds without surface water discharge.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

However, a laboratory report indicates that in 2009, TN concentrations were approximately 0.53 mg/L

and TP concentrations were approximately 0.024 mg/L for Outfall D-004 (FDEP, 2009a). There are no

effluent limits for TN and TP in the current permit. Exhibit 9 summarizes these data.

Exhibit 9: Effluent Data Summary, Progress Energy Florida, Anclote Plant

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Existing Effluent Limit

(mg/L)

Outfall D-004

TN 1 0.53 None

TP 1 0.024 None

Source: FDEP (2009a)

1. Data from 2009 laboratory report.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.31 mg/L and 0.011 mg/L,

respectively, for the Anclote Offshore segment (Segment ID 0805) of the Anclote Sound, located in the

Spring Coast watershed.
20

Analysis of FDEP’s IWR data for the segment indicates that the water may not be in compliance with the

proposed criteria. Thus, EPA assumes the discharger would not receive dilution under the proposed rule.

Exhibit 10 summarizes the RP analysis and estimated projected effluent limits for the facility.

Exhibit 10: Reasonable Potential Analysis, Progress Energy Florida, Anclote Plant

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

TN 0.53 0.60 0.31 Yes 0.31

TP 0.024 0.028 0.011 Yes 0.011

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because analysis of the ambient data indicates that the segment may not be in

compliance with the proposed criteria.

The exhibit indicates that the facility would likely have RP under the proposed rule for both TN and TP

because the average effluent concentrations exceed the proposed criteria. Based on average effluent

concentrations, the facility would not be in compliance with the projected effluent limit for TN or TP and

may need to implement some incremental level of control. However, due to the extremely low TN and TP

criteria, there is significant uncertainty as to whether the projected effluent limits are technologically or

economically feasible to attain. In addition, influent data for cooling water from EPA’s ICIS-NPDES

database indicates that average nutrient concentrations of the influent water are 0.8 mg/L for TN and

0.189 mg/L for TP (represents an average of three maximum monthly values from 2011), which exceed

the effluent concentrations for both TN and TP observed in 2009 (FDEP, 2009a). Thus, it is possible that

the majority of the nutrients in the effluent are due to nutrients in the influent waters. Further, EPA (2009)

indicates that nutrients are not likely present in once-through cooling water and cooling tower blowdown.

Given the lack of existing permit requirements, the existing low TN and TP effluent concentrations and

higher influent concentrations, and the nature of the wastewater (i.e., mainly once-through cooling water),

it is unlikely that the plant is a significant contributor of nutrients. Thus, EPA assumes that the discharger

would receive intake credits and have effluent limits based on not increasing nutrients in the effluent,

resulting in no incremental controls.
21

Progress Energy Florida, Crystal River Plant Units 1, 2, and 3

NPDES permit number: FL0000159

Major/minor: Major

SIC code: 4911(Electrical Services)

Industrial Category: Electrical Services

Design Flow: 1,898 mgd

Average Flow: 1,281 mgd (average of average monthly values from 2006 through 2010)

Receiving Water: Onsite discharge canal to the Springs Coast watershed in the Gulf of

Mexico

Description

Progress Energy Florida, Crystal River Plant Units 1, 2, and 3 discharges wastewater from two electric

generating, pulverized coal powered units (Units 1 and 2), and a nuclear powered unit (Unit 3) with a

combined capacity of 1,855 megawatts. Unit 3 in not currently in operation due to structural repairs and is

not expected to be operational until 2014. Units 4 and 5 within the complex are covered under a separate

NPDES permit (FL0036366). Units 1-5 in this complex receive water once through cooling water through

an onsite intake canal and discharge effluent to an onsite discharge canal. Both the onsite intake and

discharge canals are connected to the Springs Coast in the Gulf of Mexico.

Progress Energy Florida’s Crystal River Plant performs filtration and or other biocide treatment of oncethrough noncontact condenser cooling water the following treatment on once-through cooling water. The

facility performs neutralization, settling, filtration and/or oil/water separation for low volume wastewaters

and metal cleaning wastes.

Progress Energy Florida’s Crystal River Plant discharges once-through cooling water from Units 1, 2 and

3 through Outfalls D-011, D-012 and D-013, respectively, to the onsite discharge canal. Once-through

cooling water receives additional cooling through the helper cooling towers system, which is then

discharged into the site discharge canal through D-071 and D-072. Intake screen washwater is discharged

though Outfalls D-091, D-092, D-093, and D-094 to the onsite discharge canal. An emergency backup

water supply pump for U.S. Nuclear Regulatory Commission testing may discharge to the onsite intake

canal through Outfall D-095. Stormwater is discharged from the facility through Outfalls D-100, D-200,

D-300, D-400, D-500 and D-600 to either the onsite intake canal or onsite discharge canal.

Progress Energy Florida’s Crystal River Plant discharges non-cooling wastewaters including effluent

from the industrial wastewater pond system through D-C2R to the onsite discharge canal. Numerous

effluents are discharged through Outfall D-00F to the onsite discharge canal. The primary effluent in

Outfall D-00F is effluent from the nuclear services and decay heat seawater system, however, this stream

is combined with low volume effluents from Internal Outfall I-0FE, effluent from the laundry and shower

sump tanks; Internal Outfall I-0FE, effluent from the regeneration waste neutralization tank (which

includes metal cleaning waste); and effluent from the evaporator condensate storage tank and condensate

system (these streams are not separately monitored). Coal pile runoff is discharged to a nearby salt march

through Outfall D-00H.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

However, a laboratory report indicates that in 2009, TN concentrations were approximately 0.555 mg/L

and TP concentrations were approximately 0.048 mg/L for Outfall D-072 and TN concentrations were

approximately 0.722 mg/L and TP concentrations were approximately 0.093 mg/L for Outfall D-00F.
22

(FDEP, 2010b). There are no effluent limits for TN and TP in the current permit. Exhibit 11 summarizes

these data.

Exhibit 11: Effluent Data Summary, Progress Energy Florida, Crystal River Plant Units 1, 2 and 3

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Existing Effluent Limit

(mg/L)

Outfall D-072

TN 1 0.555 None

TP 1 0.048 None

Outfall D-00F

TN 1 0.722 None

TP 1 0.093 None

Source: FDEP (2010b)

1. Data from 2009 laboratory report.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.36 mg/L and 0.013 mg/L,

respectively, for the Crystal-Homosassa Offshore segment (Segment ID 0813) in the Springs Coast

watershed in the Gulf of Mexico.

Analysis of FDEP’s IWR data for the segment indicates that the water may not be in compliance with the

proposed criteria. Thus, EPA assumes the discharger would not receive dilution under the proposed rule.

Exhibit 12 summarizes the RP analysis and estimated projected effluent limits for the facility.

Exhibit 12: Reasonable Potential Analysis, Progress Energy Florida, Crystal River Plant Units 1, 2

and 3

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

Outfall D-072

TN 0.555 0.52 0.36 Yes 0.36

TP 0.048 0.038 0.013 Yes 0.013

Outfall D-00F

TN 0.722 0.52 0.36 Yes 0.36

TP 0.093 0.038 0.013 Yes 0.013

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because analysis of the ambient data indicates that the segment may not be in

compliance with the proposed criteria.

The exhibit indicates that the facility would likely have RP under the proposed rule for both TN and TP

for both outfalls because the average effluent concentrations exceed the proposed criteria. Based on

average effluent concentrations, the facility would not be in compliance with the projected effluent limit

for TN or TP and may need to implement some incremental level of control.

Outfall D-072 is mainly once-through cooling water which is not likely to contain significant nutrient

concentrations based on data from U.S. EPA (2009). The intake water is from the Springs Coast, with

nutrient concentrations similar to those in the discharge (see Exhibit 12 above). Thus, EPA assumes that

the discharger would likely receive intake credits for compliance with effluent limits and incremental

controls and costs are not likely.
23

For Outfall D-00F, there is significant uncertainty as to whether the projected effluent limits are

technologically or economically feasible to attain. Thus, EPA estimates costs based on the assumption of

a variance from meeting effluent limits based on criteria end-of-pipe. While existing TN concentrations

are already relatively low, additional reductions in TP could be achieved through cost-effective treatment

controls. Thus, EPA estimated incremental compliance costs based on installation of chemical

precipitation followed by filtration as a condition of the variance (i.e., lowest levels feasible).

Capital and O&M unit costs associated with this treatment could be $0.32/gpd and $238/MG,

respectively. EPA assumes that treatment would be required only on effluent from the laundry and shower

sump tanks (Internal Outfall I-0FE) and effluent from the regeneration waste neutralization tank (Internal

Outfall I-0FG) and not the other wastewater components of Outfall D-00F (i.e., mainly nuclear services

and decay heat seawater system effluent) because it is not likely to contain nutrients. The facility’s permit

does not report design flows from which to estimate total capital costs. Therefore, to estimate capital

costs, EPA used the 90th percentile maximum monthly flow for both outfalls from 2006 through 2011 to

approximate the necessary design flow (0.0015 mgd for Outfall I-0FE and 0.0831 mgd for Outfall I-0FG).

Based on these flows, total capital costs would be approximately $0.027 million. During the last 5 years,

average maximum monthly flows for Outfall I-0FE and Outfall I-09FG have been 0.0010 mgd and 0.0796

mgd, respectively. Thus, based on these flows and assuming operation of the treatment units 365 days per

year, O&M costs could be approximately $0.0070 million. Total annual costs would be $0.0096 million

based on annualizing capital costs at 7% over 20 years and adding annual O&M. Exhibit 13 summarizes

these costs.

Exhibit 13: Potential Incremental Costs, Progress Energy Florida, Crystal River Plant Units 1, 2

and 3

Treatment Controls Capital Costs

($ million)1

O&M Cost

($ million/year)2

Annual Costs

($ million/year)3

Chemical precipitation

with filtration $0.027 $0.0070 $0.0096

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of

operating days per year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.

For the remaining external outfalls, there are no effluent data from which to assess compliance and the

facility does not have existing effluent limits or monitoring requirements for TN or TP. Given the lack of

existing permit requirements, potential for intake credits, and the nature of the wastewater (i.e., mainly

once-through cooling water and stormwater), it is unlikely that the facility would have reasonable

potential under the proposed rule for the remaining external outfalls. Thus, incremental compliance costs

are likely zero for the remaining external outfalls.
24

Progress Energy Florida, Crystal River Plant Units 4 and 5

NPDES permit number: FL0036366

Major/minor: Major

SIC code: 4911 (Electrical Services)

Industrial Category: Electrical Services

Design Flow: 44 mgd for Outfalls D-074 and D-075

Average Flow: 45.6 mgd for Outfall D-074 and 39.3 mgd for Outfall D-075 (average of

maximum monthly values for 2006 – 2011); 12.4 mgd for Outfall D-0C0

from a single observation in 2008

Receiving Water: Onsite discharge canal to the Springs Coast watershed in the Gulf of

Mexico

Description

Progress Energy Florida, Crystal River Plant Units 4 and 5 discharge wastewater from of two electric

generating, coal-fired units (Units 4 and 5) with a total capacity rating of 1,390 megawatts. Units 1, 2 and

3 within the complex are covered under a separate NPDES permit (FL0000159). Units 1-5 receive water

once through cooling water through an onsite intake canal and discharge effluent to an onsite discharge

canal. Both the onsite intake and discharge canals are connected to the Springs Coast in the Gulf of

Mexico.

Progress Energy Florida, Crystal River Plant Units 4 and 5 performs chlorination in the noncontact

recirculating cooling tower water from Units 4 and 5. Noncontact recirculating cooling tower blowdown

is discharged through Outfalls D-074 and D-075 to the onsite discharge canal. Stormwater runoff from the

coal storage area, ash landfill runoff, ash sluice and dewatering system, and fly/bottom ash transport truck

rinsate is treated by sedimentation in the collection areas. In the rare event of an overflow of the

collection areas, runoff collected from the coal storage area and ash landfill area are discharged by

Internal Outfalls I-CHO and I-C40, respectively, through Outfall D-0CO to the onsite discharge canal.

Summary of Effluent Data and Limits

TN and TP data are not available from EPA’s ICIS-NPDES database. However, a laboratory report

indicates that in 2004, TN concentrations were approximately 0.53 mg/L and TP concentrations were

approximately 0.072 mg/L for Outfall D-075 (FDEP, 2004a). There are no effluent limits for TN and TP

in the current permit. Exhibit 14 summarizes these data.

Exhibit 14: Effluent Data Summary, Progress Energy Florida, Crystal River Plant Units 4 and 5

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Existing Effluent Limit

(mg/L)

Outfall D-075

TN 1 0.53 None

TP 1 0.072 None

Source: FDEP (2004a)

1. Data from 2004 laboratory report.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.36 mg/L and 0.013 mg/L,

respectively, for the Crystal-Homosassa Offshore segment (Segment ID 0813) in the Springs Coast

watershed in the Gulf of Mexico.
25

Analysis of FDEP’s IWR data for the segment indicates that the water may not be in compliance with the

proposed criteria. Thus, EPA assumes the discharger would not receive dilution under the proposed rule.

Exhibit 15 summarizes the RP analysis and estimated projected effluent limits for the facility.

Exhibit 15: Reasonable Potential Analysis, Progress Energy Florida, Crystal River Plant Units 3

and 4

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

TN 0.53 0.52 0.36 Yes 0.36

TP 0.072 0.038 0.013 Yes 0.013

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because analysis of the ambient data indicates that the segment may not be in

compliance with the proposed criteria.

The exhibit indicates that the facility would likely have RP under the proposed rule for both TN and TP

because the average effluent concentrations exceed the proposed criteria. Based on average effluent

concentrations, the facility would not be in compliance with the projected effluent limit for TN or TP and

may need to implement some incremental level of control. However, Outfall D-075 is mainly oncethrough cooling water which is not likely to contain significant nutrient concentrations based on data from

U.S. EPA (2009). Also, the intake water is from the Springs Coast with nutrient concentrations similar to

those in the discharge (see Exhibit 15 above). Thus, EPA assumes that the discharger would likely receive

intake credits for compliance with effluent limits and incremental controls and costs are not likely.

For the remaining external outfalls, there are no effluent data from which to assess compliance and

Progress Energy does not have existing effluent limits or monitoring requirements for TN or TP at the

Crystal River Plant Units 4 and 5. Given the lack of existing permit requirements and the nature of the

wastewater (i.e., mainly once-through cooling water and stormwater), it is unlikely that Progress Energy

would have RP under the proposed rule for the remaining external outfalls. Thus, incremental compliance

costs are likely zero.
26

Vero Beach Municipal Power Plant

NPDES permit number: FL0002984

Major/minor: Major

SIC code: 4911 (Electrical Services)

Industrial Category: Electrical Services

Design Flow: 217 mgd

Average Flow: 5.7 mgd for outfall D-011, 12.4 mgd for outfall D-012 and 34.4 mgd for

outfall D-013 (average of average monthly values from 2006 through

2011)

Receiving Water: Indian River Lagoon

Description

Vero Beach Municipal Power Plant is an electric generating plant with five units and a total capacity of

157 megawatts. The plant contains four steam electric generating units (Units 1, 2, 3 and 4) and a

combined-cycle gas turbine unit (Unit 5). Each of the steam electric units can burn a variable combination

of No. 2, No. 4 and No. 6 fuel oil and natural gas.

Units 1, 2 and 3 are permitted to draw a maximum of 217 mgd from the Indian River Lagoon as oncethrough noncontact cooling water and discharge it back into the Indian River Lagoon with no treatment

through Outfalls D-011, D-012, and D-013. Unit 4 obtains treated wastewater effluent from the Vero

Beach Waste Water Treatment Plant to use for its cooling tower. The cooling tower blowdown is returned

to the wastewater treatment plant. Unit 5 is equipped with a closed-loop auxiliary cooling water system.

Units 4 and 5 are not permitted to discharge to Florida waters. Uncontaminated stormwater is also

discharged to the Indian River Lagoon through Outfalls D-0S1, D-0S2, D-0S3, and D-0S6. Stormwater

discharge from fuel oil tanks 1 and 2 bermed areas are discharged to the Indian River via Outfall D-00B.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

However, a laboratory report indicates that in 2004, TN concentrations were approximately 0.2 mg/L and

there was no detection for phosphorous for Outfall D-00B (FDEP, 2004b). There are no effluent limits for

TN and TP in the current permit. Exhibit 16 summarizes these data.

Exhibit 16: Effluent Data Summary, Vero Beach Municipal Power Plant

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L)1

Existing Effluent Limit

(mg/L)

Outfall D-075

TN 1 0.20 None

TP 1 <0.02 None

Source: FDEP (2004b)

1. Data from 2004 laboratory report.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 1.12 mg/L and 0.117 mg/L,

respectively, for the Lower Central Indian River Lagoon segment (Segment ID 1505) in the Indian River

Lagoon.
27

Exhibit 17 summarizes the RP analysis and estimated projected effluent limits for TP for the facility.

Exhibit 17: Reasonable Potential Analysis, Vero Beach Municipal Power Plant

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

TN 0.20 0.66 1.12 No

TP <0.02 0.072 0.117 No

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

The exhibit indicates that the facility does not have RP because effluent concentrations for TN and TP are

below the proposed criteria. Thus, EPA assumes that the facility would not incur incremental costs

associated with TN or TP reductions.

In addition, for those outfalls for which data are not available, EPA assumes that incremental compliances

costs are not likely because the facility is not considered a source of nutrients and does not have nutrient

loading or effluent targets in the Indian River TMDL (Gao, 2009). Also, the lack of existing permit

requirements and the nature of the wastewater (e.g., mainly once-through cooling water and stormwater),

suggest that the facility is not likely to have RP under the proposed.
28

Food

Tropicana Manufacturing Company, Inc

NPDES permit number: FL0000043

Major/minor: Major

SIC code: 0174 (Citrus Fruits)

Industrial Category: Food

Design Flow: 2.26 mgd

Average Flow: No discharge since 2003

Receiving Water: Manatee River

Description

Tropicana Manufacturing Company, Inc. operates a citrus juice processing plant with processes fresh fruit

during the harvesting season (November through June) and packages the juice on a year-round basis. The

process wastewater from the production facility is treated in an onsite, multi-stage wastewater treatment

plant which consists of equalization, dissolved air flotation, anaerobic bioreactors, pH adjustment, and 2nd

stage activated sludge (aeration and secondary clarification), and tertiary dissolved air flotation. Treated

effluent is stored or discharged to an underground injection well or Manatee River.

Summary of Effluent Data and Limits

The facility has not discharged in the last five years; thus, there are no effluent data for TN and TP.

However, the discharge has an annual loading limit for TN of 9.125 tons/year based on a 5-year rolling

average with a 1-year maximum load not to exceed 13.6875 tons.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.62 mg/L and 0.115 mg/L,

respectively, for the Manatee River (Segment ID 0906). However, because the facility has not discharged

within the last five years, EPA assumes that it would not have RP under the proposed rule and would be

unlikely to incur incremental control costs.
29

Anheuser Busch Inc., Main Street Sod Farm

NPDES permit number: FL0041530

Major/minor: Minor

SIC code: 2082 (Malt Beverages)

Industrial Category: Food

Design Flow: 2.4 mgd

Average Flow: 1.02 mgd (average of annual average values from 2006 through 2010)

Receiving Water: Little Cedar Creek to Broward River

Description

Anheuser Busch Inc. operates a land application system that receives untreated and/or pretreated brewery

liquor as a nutrient enrichment to grow turf and forage crops on a 320-acre site. The land application site

drains to an interconnected pond system composed of two ponds: North Borrow Pit and South Borrow

Pit. North Borrow Pit drains to South Borrow Pit, which discharges via Outfall D-001 to Little Cedar

Creek, and thence to the Broward River and ultimately to the Saint Johns River.

Summary of Effluent Data and Limits

Exhibit 18 summarizes average monthly effluent data for TN and TP from 2005 to 2010.

Exhibit 18: Effluent Data Summary, Anheuser Busch Inc., Main Street Sod Farm

Pollutant Number of

Observations

Average Effluent

(mg/L)1 Permit Limit2

Outfall D-001

TN 55 3.0 None

TP 20 1.3 None

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values.

2. Permit contains an annual loading limit for TN of 27,000 lbs/year.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 1.09 mg/L and 0.108 mg/L,

respectively, for the St. Johns River estuary (Segment ID 1802).

Anheuser Busch Inc. is already covered under the Lower St. Johns River TMDL and Basin Management

Action Plan (BMAP). EPA assumes that the TMDL targets would be adopted as SSAC. FDEP gave the

discharger a TN WLA that represented a 49% decrease in TN. To reduce effluent nutrient loads, in 2006,

Anheuser Busch improved/modified the site nutrient management plan and increased the crop area to

which they land applied a portion of the wastewater to reduce the nutrient load per acre (Busby, 2009).

Thus, EPA assumes that the discharger would not be required to implement additional controls for

compliance with TN limits under the proposed rule.

Analysis of FDEP’s IWR data for the segment indicates that the water may not be in compliance with the

proposed TP criterion. Thus, EPA assumes the discharger would not receive dilution under the proposed

rule. Exhibit 19 summarizes the RP analysis and estimated projected effluent limits for TP for the

facility.
30

Exhibit 19: Reasonable Potential Analysis, Anheuser Busch Inc., Main Street Sod Farm

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

TP 1.3 0.12 0.108 Yes 0.108

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because analysis of the ambient data indicates that the segment may not be in

compliance with the proposed criteria.

The exhibit indicates that the facility would likely have RP under the proposed rule for TP because the

average effluent concentration exceeds the proposed criteria. Based on average effluent concentrations,

the facility would not be in compliance with the projected effluent limit for TP and may need to

implement some incremental level of control.

Due to a lack of site-specific facility operations and treatment data, it is uncertain whether additional

improvements or modifications similar to those made to reduce TN concentrations could be made to

reduce TP concentrations. However, to be conservative (i.e., erring on the side of estimating greater

impact and higher costs under the proposed rule), EPA estimates costs to meet the potential TP levels

based on installing chemical precipitation followed by filtration. Capital and O&M unit costs could be

$0.32/gpd and $238/MG, respectively. Based on a design flow of 2.4 mgd, total capital costs could be

approximately $0.77 million. During the last 5 years, average maximum monthly flows have been

approximately 1.02 mgd. Thus, assuming operation of the treatment units 365 days per year, O&M costs

could be approximately $0.089 million. Total annual costs would be $0.16 million based on annualizing

capital costs at 7% over 20 years and adding annual O&M. Exhibit 20 summarizes these costs.

Exhibit 20 : Potential Incremental Costs, Anheuser Busch Inc., Main Street Sod Farm

Treatment Controls Capital Costs

($ million)1

O&M Cost

($ million/year)2

Annual Costs

($ million/year)3

Chemical precipitation

with filtration $0.77 $0.089 $0.16

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of

operating days per year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
31

Pulp and Paper

Rayonier Performance Fibers, LLC

NPDES permit number: FL0000701

Major/minor: Major

SIC code: 2611 (Pulp Mills)

Industrial Category: Pulp and Paper

Design Flow: 26.31 mgd

Average Flow: 16.8 mgd (average of maximum monthly values from 2006 through

2010)

Receiving Water: Amelia River

Description

Rayonier Performance Fibers, LLC is a chemical cellulose pulp mill using the sulfite process. Wastewater

treatment consists of a grit chamber, neutralization, primary clarifier, and a 34-acre mechanical aeration

lagoon. The facility discharges treated process wastewater, treated stormwater, rinse water, and regenerate

water from the water treatment plant zeolite softening units to Amelia River only during outgoing tides.

Summary of Effluent Data and Limits

TN and TP data are not available from EPA’s ICIS-NPDES database. However, a laboratory report

indicates that in 2009, TN concentrations were approximately 42.2 mg/L and TP concentrations were

approximately 1.6 mg/L (FDEP, 2011b). There are no effluent limits for TN and TP in the current permit.

Exhibit 21 summarizes these data.

Exhibit 21: Effluent Data Summary, Rayonier Performance Fibers, LLC

Pollutant Number of

Observations

Average Effluent

Concentration (mg/L) Permit Limit

Outfall 001

TN 1 42.2 None

TP 1 1.6 None

Source: FDEP (2011b)

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.27 mg/L and 0.045 mg/L,

respectively, for the Lower Amelia River (Segment ID 2002) in the St. Mary’s Estuary.

There are limited data (two observations for TN and TP each from 2011) available for the segment in

FDEP’s IWR database. This data indicates that the segment may not be in compliance with the proposed

TN and TP criteria. Thus, EPA assumes the discharger would not receive dilution under the proposed

rule. Exhibit 22 summarizes the RP analysis and estimated projected effluent limits for TN and TP for

the facility.
32

Exhibit 22: Reasonable Potential Analysis, Rayonier Performance Fibers, LLC

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

TN 42.2 0.59 0.27 Yes 0.27

TP 1.6 0.067 0.045 Yes 0.045

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because analysis of the ambient data indicates that the segment may not be in

compliance with the proposed criteria.

The exhibit indicates that the facility would likely have RP under the proposed rule for TN and TP

because the average effluent concentrations exceed the proposed criterion. Based on average effluent

concentrations, the facility would not be in compliance with the projected effluent limit for TN or TP and

may need to implement some incremental level of control.

However, due to the low TN and TP criteria, there is significant uncertainty as to whether the projected

effluent limits are feasible to attain. Thus, EPA estimates costs based on the assumption of a variance

from meeting the projected effluent limits; the appendix provides analysis of an alternative treatment

scenario. Because existing TN and TP discharge concentrations are high compared to levels that can be

achieved with cost-effective treatment controls such as advanced biological nutrient removal (BNR), EPA

assumes that the facility would need to reduce TN and TP as a condition of the variance (i.e., lowest

levels feasible). Thus, EPA estimated incremental compliance costs based on installation of advanced

BNR.

Capital and O&M unit costs could be $1.30/gpd and $385/MG, respectively. Based on a design flow of

26.31 mgd, total capital costs could be approximately $36.0 million. During the last 5 years, average

maximum monthly flows have been 16.8 mgd. Thus, to estimate O&M costs EPA used these average

flows assuming operation of the treatment units 365 days per year at a cost of $2.5 million. Total annual

costs would be $5.9 million based on annualizing capital costs at 7% over 20 years and adding annual

O&M. Exhibit 23 summarizes these costs.

Exhibit 23: Potential Incremental Costs, Rayonier Performance Fibers, LLC

Treatment Controls Capital Costs

($ million)1

O&M Cost

($ million/year)2

Annual Costs

($ million/year)3

Advanced BNR $36.0 $2.5 $5.9

1. Design flow multiplied by unit cost of $1.30/gpd for advanced BNR.

2. Average flow multiplied by unit cost of $385/MG for advanced BNR and the number of operating days per year

(365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
33

Smurfit Stone, Fernandina Beach Containerboard Mill

NPDES permit number: FL0001104

Major/minor: Major

SIC code: 2631 (Paperboard Mills)

Industrial Category: Pulp and Paper

Design Flow: 37.5 mgd

Average Flow: 17.1 mgd (average of maximum monthly values from 2006 through

2010)

Receiving Water: Lower Amelia River

Description

Smurfit Stone, Fernandina Beach Containerboard Mill produces unbleached Kraft linerboard through the

following processes: wood preparation, pulping, pulp processing and chemical recovery, and paper and

paperboard manufacturing, all of which contribute to production of wastewater. Wastewater treatment

consists of a grit chamber, bar screen, primary clarifier, heat exchanger, cooling tower (for noncontact

cooling water), pure oxygen activated sludge treatment system, and dual secondary clarifiers. The facility

dewaters primary and secondary solids using screw presses and belt presses. The facility discharges to

Lower Amelia River.

Summary of Effluent Data and Limits

Average monthly effluent data for TP are available from 2006 to 2010 from EPA’s ICIS-NPDES

database. TN data are not available from EPA’s ICIS-NPDES database, however, the average total

Kjeldahl nitrogen concentration from 2006 to 2010 is approximately 3.8 mg/L (based on 19 observations

of the maximum monthly value). Total Kjeldahl nitrogen is the sum of organic nitrogen, and ammonia

and ammonium as nitrogen, and can be used to estimate TN by adding the concentrations of nitrate and

nitrite as nitrogen. A laboratory report for this facility indicates that nitrate and nitrite as nitrogen

concentrations were insignificant (0.004 mg/L) relative to total Kjeldahl nitrogen levels (FDEP, 2009d).

Thus, total Kjeldahl nitrogen levels can be used as a proxy for TN for this analysis. Exhibit 24

summarizes these data.

Exhibit 24: Effluent Data Summary, Smurfit Stone, Fernandina Beach Containerboard Mill

Pollutant Number of

Observations

Average Effluent

(mg/L)1 Permit Limit (mg/L)

TN 19 3.8 None

TP 19 0.47 None

Source: EPA (2011)

1. TN data calculated as the average of 18 TKN observations plus nitrate and nitrite concentration from FDEP

(2009d). TP effluent data from 2006 through 2010 represent average of maximum monthly values.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.27 mg/L and 0.045 mg/L,

respectively, for the Lower Amelia River (Segment ID 2002) in the St. Mary’s Estuary.

There are limited data (two observations for TN and TP each from 2011) available for the segment in

FDEP’s IWR database. This data indicates that the segment may not be in compliance with the proposed

TN and TP criteria. Thus, EPA assumes the discharger would not receive dilution under the proposed rule

even though the discharger has a mixing zone for the calculation of effluent limits for dissolved oxygen,
34

copper, nickel, and temperature with a dilution ratio of 32:1 in its existing permit. Exhibit 25 summarizes

the RP analysis and estimated projected effluent limits for TN and TP for the facility.

Exhibit 25: Reasonable Potential Analysis, Smurfit Stone, Fernandina Beach Containerboard Mill

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

TN 3.8 0.59 0.27 Yes 0.27

TP 0.47 0.067 0.045 Yes 0.045

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because the ambient data are limited and the existing permit does not provide

dilution for effluent limits.

The exhibit indicates that the facility would likely have RP under the proposed rule for TN and TP

because the average effluent concentrations exceed the proposed criterion. Based on average effluent

concentrations, the facility would not be in compliance with the projected effluent limit for TN or TP and

may need to implement some incremental level of control.

However, due to the low TN and TP criteria, there is significant uncertainty as to whether the projected

effluent limits are feasible to attain. Thus, EPA estimates costs based on the assumption of a variance

from meeting the projected effluent limits; the appendix provides analysis of an alternative treatment

scenario. Because existing TN and TP discharge concentrations are high compared to levels that can be

achieved with cost-effective treatment controls such as advanced BNR, EPA assumes that the facility

would need to reduce TN and TP as a condition of the variance (i.e., lowest levels feasible). Thus, EPA

estimated incremental compliance costs based on installation of advanced BNR.

Capital and O&M unit costs could be $1.30/gpd and $385/MG, respectively. Based on a design flow of

37.5 mgd, total capital costs could be approximately $51.3 million. During the last 5 years, average

maximum monthly flows have been 17.1 mgd. Thus, to estimate O&M costs EPA used these average

flows assuming operation of the treatment units 365 days per year at a cost of $2.5 million. Total annual

costs would be $5.9 million based on annualizing capital costs at 7% over 20 years and adding annual

O&M. Exhibit 26 summarizes these costs.

Exhibit 26: Potential Incremental Costs, Smurfit Stone, Fernandina Beach Containerboard Mill

Treatment Controls Capital Costs

($ million)1

O&M Cost

($ million/year)2

Annual Costs

($ million/year)3

Advanced BNR $51.3 $2.5 $7.3

1. Design flow multiplied by unit cost of $1.30/gpd for advanced BNR.

2. Average flow multiplied by unit cost of $385/MG for advanced BNR and the number of operating days per year

(365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
35

Smurfit Stone, Seminole Mill

NPDES permit number: FL0000400

Major/minor: Major

SIC code: 2611 (Pulp Mills)

Industrial Category: Pulp and Paper

Design Flow: 20 mgd

Average Flow: 7.4 mgd (average of maximum monthly values from 2006 through 2010)

Receiving Water: Saint Johns River

Description

The facility generates pulp with an onsite recycling pulp operation or the purchase of bleached pulp. The

Saint John’s River BMAP indicates that the facility changed from a pulp and paper mill to a recycling

mill in the 1990s, reducing the volume of effluent. Wastewater treatment consists of grit removal, primary

clarification, and aeration in two unlined holding ponds and an unlined aeration stabilization basin. The

facility also includes an onsite landfill and sludge drying beds which process nonhazardous solid waste

material from onsite operations and activities. The facility discharges treated process wastewater and

sanitary wastewater to the Saint John’s River.

Summary of Effluent Data and Limits

Exhibit 27 summarizes average monthly effluent data for TN and TP from 2006 to 2010.

Exhibit 27: Effluent Data Summary, Smurfit Stone, Seminole Mill

Pollutant Number of

Observations

Average Effluent

(mg/L)1 Permit Limit (mg/L)2

TN 31 4.8 None

TP 14 0.41 None

Source: EPA (2011)

1. TN and TP effluent data from 2006 through 2010. Represents average of maximum monthly values.

2. Permit contains an annual load based limit for TN of 74,305 kg/year.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 1.09 mg/L and 0.108 mg/L,

respectively, for the St. John’s River (Segment ID 1802).

The facility is covered under the Lower St. John’s River TMDL and BMAP, which set targets for TN

only. The BMAP indicates that no additional reductions are needed for compliance with the facility’s

WLA (it has already achieved twice as many reductions as needed for the TMDL). Thus, assuming the

existing TN TMDL target is adopted as a SSAC, there would be no incremental costs associated with TN

reductions under the proposed rule.

However, for TP, analysis of FDEP’s IWR data for the segment indicates that the water may not be in

compliance with the proposed TP criterion. Thus, EPA assumes the discharger would not receive dilution

under the proposed rule. Exhibit 28 summarizes the RP analysis and estimated projected effluent limits

for TP for the facility.
36

Exhibit 28: Reasonable Potential Analysis, Smurfit Stone, Seminole Mill

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

TP 0.41 0.12 0.108 Yes 0.108

NA = not available.

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because analysis of the ambient data indicates that the segment may not be in

compliance with the proposed criteria.

The exhibit indicates that the facility would likely have RP under the proposed rule for TP because the

average effluent concentration exceeds the proposed criterion. Based on average effluent concentrations,

the facility would not be in compliance with the projected effluent limit for TP and may need to

implement some incremental level of control.

However, due to a lack of site-specific facility operations and treatment data, it is uncertain whether

additional improvements or modifications could be made to reduce TP concentrations. As such, EPA

conservatively (i.e., erring on the side of estimating greater impact and higher costs under the proposed

rule) estimates costs based on installation of chemical precipitation followed by filtration.

Capital and O&M unit costs could be $0.32/gpd and $238/MG, respectively. Based on a design flow of

20 mgd, total capital costs could be approximately $6.4 million. During the last 5 years, average

maximum monthly flows have been approximately 7.4 mgd. Thus, assuming operation of the treatment

units 365 days per year, O&M costs could be approximately $0.64 million. Total annual costs would be

$1.3 million based on annualizing capital costs at 7% over 20 years and adding annual O&M. Exhibit 29

summarizes these costs.

Exhibit 29: Potential Incremental Costs, Smurfit Stone – Seminole Mill

Treatment Controls Capital Costs

($ million)1

O&M Cost

($ million/year)2

Annual Costs

($ million/year)3

Chemical precipitation

with filtration $6.4 $0.64 $1.3

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of

operating days per year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
37

Other

BP Products North America, Port Everglades North and South Terminal

NPDES permit number: FL0044148

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd for Outfall D-002 and 0.5 mgd for Outfall D-003

Average Flow: No discharges in the past five years

Receiving Water: Intracoastal Waterway

Description

BP Products North America, Port Everglades North and South Terminals are bulk petroleum storage and

distribution facilities consisting of two separate north tank farm and south tank farm terminal sites. The

north terminal operation includes four main storage tanks for unleaded gasoline and denatured ethanol

(with a total storage capacity of 12 MG), a fifth decommissioned tank, and two smaller tanks (10,000

gallon) for petroleum contact water. The north terminal is surrounded by an unlined secondary

containment area. The south terminal operation consists of three main storage tanks for unleaded gasoline

and denatured ethanol (with a total storage capacity of 15 MG) and one smaller tank for petroleum

contact water. The south terminal is surrounded by a lined secondary containment area and unlined

retention-percolation pond (32,000 sq. ft.). The sites are connected allowing for the transmission of fuel

products or wastewater between the two terminals.

Hydrostatic test water and stormwater is discharged through Outfalls D-001 (north terminal) and D-002

(south terminal) to an unnamed drainage ditch. From the unnamed drainage ditch, the discharge proceeds

to the Eller Drive ditch, and then to the Florida Power and Light cooling water discharge canal (which

also receives effluent from Florida Power and Light, Lauderdale Plant, FL0001538, and other NPDES

permitted dischargers), which ultimately discharges into the Intracoastal Waterway. Hydrostatic test water

is normally discharged untreated, although the permit requires analysis prior to discharge to ensure that

effluent limitations are met. Disposal of stormwater is normally by percolation and evaporation. However,

stormwater may be discharged through the outfalls either without treatment if no oil sheen is present or

after treatment with an oil/water separator. Petroleum contact water, including tank bottom water and

loading rack runoff, is collected and ultimately hauled offsite for disposal.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

BP Products North America, Port Everglades North and South Terminals discharges to coastal waters, for

which EPA has proposed only chlorophyll-a criterion. While there are no TN and TP criteria, EPA

assumes that BP Products North America would be required to meet the concentrations associated with

economically feasible treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for

exceeding the chlorophyll-a criterion. However, BP Products North America does not have effluent limits

or monitoring requirements for TN or TP at the Port Everglades North and South Terminals. Given the

lack of permit requirements and the nature of the wastewater (i.e., hydrostatic test water and stormwater)

and that no discharges have occurred in the past five years, it is unlikely that the facility would have

reasonable potential under the proposed rule. Thus, incremental compliance costs are likely zero.
38

Chevron Products Company, Panama City Terminal

NPDES permit number: FL0175480

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: Not reported

Average Flow: No discharges in the past five years

Receiving Water: St. Andrews Bay

Description

Chevron Products Company, Panama City Terminal is a bulk petroleum storage terminal which receives,

stores and transfers petroleum products including gasoline, jet fuel, diesel fuel and petroleum additives.

The wastewater consists of petroleum contact water generated from stormwater runoff, tanker truck

loading rack wash down, storage tank water draw off and groundwater collection. Combined wastewaters

are treated with an oil/water phase separator and are then disposed of in an onsite 3.4 million gallon

evaporation storage tank. The tank includes an internal spray system which accelerates evaporation and

volatilization of organics. Wastewater is only discharged in the event of prolonged rainfall that causes the

evaporation storage tank to overflow. In case of such an event, the excess wastewater is discharged into

St. Andrews Bay.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.19 mg/L and 0.016 mg/L,

respectively, for the Western St. Andrews Bay (Segment ID 0404) in the St. Andrews Bay Estuary.

However, there are no effluent data from which to assess compliance, and Chevron Products Company

does not have existing effluent limits or monitoring requirements for TN or TP from the Panama City

Terminal. Given the lack of existing permit requirements, the nature of the wastewater (e.g., stormwater),

and that no discharges have occurred in the past five years, it is unlikely that the facility would have

reasonable potential under the proposed rule. Thus, EPA assumes that incremental control costs under the

proposed rule are likely zero.
39

Chevron Products Company, Port Everglades Terminal

NPDES permit number: FL0043923

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd for Outfall D-001 and 0.5 mgd for Outfall D-002.

Average Flow: No discharges in the past five years

Receiving Water: Port Everglades Turning Basin

Description

Chevron Products Company, Port Everglades Terminal is a bulk petroleum storage and distribution

facility consisting of two separate east field tank farm and west field tank farm sites. At the east field,

there are 12 existing (three are being renovated) and two new major aboveground product storage tanks

units under construction. The west field consists of three existing plus two new units under construction.

The existing storage tanks store unleaded gasoline, jet fuel, and crude oil (with capacities ranging from

0.4 to 5.8 MG); while the two new tanks at the east field will store ethanol. The fields also include smaller

tanks (six at the east field and three at the west) for “Transmix” (off-spec recovered hydrocarbons),

petroleum contact water, and fuel additives (all tanks are less than 1,000 barrels). Secondary containment

for both sites involves earthen dikes and a concrete wall surrounding the unlined basins. The west field

also contains a retention pond to collect only the noncontact stormwater runoff.

Hydrostatic test water is discharged through Outfalls D-001 (eastern field) and D-002 (western field) to a

storm sewer system that empties into Slip No. 1 at the Port Everglades Turning Basin. Hydrostatic test

water is normally discharged untreated, though the permit requires analysis prior to discharge to ensure

that effluent limitations are met. Diked area stormwater is retained onsite and disposed of via percolation;

however, Chevron Products Company intends to obtain a separate Multi-Sector Generic Permit in the

future to authorize stormwater discharge. Oil/water separators and gravity settling pits treat petroleum

contact water, which includes tank bottom water and loading rack runoff. Treated petroleum contact is

stored onsite and ultimately hauled offsite for disposal.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

Chevron Products Company, Port Everglades Terminal discharges to coastal waters, for which EPA has

proposed only chlorophyll-a criterion. While there are no TN and TP criteria, EPA assumes that the

Chevron Products Company would be required to meet the concentrations associated with economically

feasible treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the

chlorophyll-a criterion. However, Chevron Products Company does not have effluent limits or monitoring

requirements for TN or TP at the Port Everglades Terminal. Given the lack of permit requirements and

the nature of the wastewater (i.e., hydrostatic test water and stormwater) and that no discharges have

occurred in the past five years, it is unlikely that the facility would have reasonable potential under the

proposed rule. Thus, incremental compliance costs are likely zero.
40

Coastal Terminals LLC, Port Everglades Terminal

NPDES permit number: FL0039969

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd for Outfall D-001 and 0.5 mgd for Outfall D-002

Average Flow: No discharges in the past five years for Outfall D-001; Intermittent, 0.48

mgd for Outfall D-002 (average of maximum monthly values from 2006

through 2011)

Receiving Water: Port Everglades Turning Basin

Description

Coastal Terminals LLC, Port Everglades Terminal is a bulk petroleum products storage and distribution

facility at Port Everglades consisting of 33 aboveground tanks at the North Terminal site. The 25 major

tanks (with capacities ranging from 0.2 to 5.0 MG) store various petroleum products including unleaded

gasoline, diesel fuel, No. 6 fuel oil, jet fuel, crude oil, and asphalt. Another seven smaller tanks (with

capacities below 30,000 gallon) store fuel additives and the remaining tank (0.3 MG) is for petroleum

contact water. The tank farm is surrounded by earthen dikes in an unlined basin.

Hydrostatic test water is discharged through Outfalls D-001 (eastern outfall) and D-002 (western outfall)

to an offsite storm sewer, which ultimately discharges into the Port Everglades Turning Basin.

Hydrostatic test water is normally discharged untreated, although the permit requires analysis prior to

discharge to ensure that effluent limitations are met. If necessary, portable water treatment equipment

(e.g., diatomaceous earth filters) may be used to reduce the particular pollutant(s) of concern; however the

effluent total residual chlorine level is usually reduced by exposure to the atmosphere during transport to

the outfall via overland flow and across the detention pond. Outfall D-002 is the preferred outfall as its

location allows for further treatment and percolation-recharge. Petroleum contact water, including tank

bottom water and loading rack runoff, is collected and ultimately hauled offsite for disposal.

Stormwater is normally disposed of by percolation and evaporation, however, stormwater discharge is

allowed by a separate Multi-Sector Generic Permit.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

Coastal Terminals LLC, Port Everglades Terminal discharges to coastal waters, for which EPA has

proposed only chlorophyll-a criterion. While there are no TN and TP criteria, EPA assumes that Coastal

Terminals LLC would be required to meet the concentrations associated with economically feasible

treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the chlorophylla criterion. However, Coastal Terminals LLC does not have effluent limits or monitoring requirements for

TN or TP for the Port Everglades Terminal. Given the lack of permit requirements and the nature of the

wastewater (i.e., hydrostatic test water), it is unlikely that the facility would have reasonable potential

under the proposed rule. Thus, incremental compliance costs are likely zero.
41

CSXT Moncrief Rail Yard and Fruit Growers Express Yard

NPDES permit number: FL0176877

Major/minor: Minor

SIC code: 4959 (Sanitary Services, Not Elsewhere Classified)

Industrial Category: Other

Design Flow: 0.138 mgd

Average Flow: No discharges in the past five years

Receiving Water: Lower St Johns River

Description

CSXT Moncrief Rail Yard and Fruit Growers Express Yard is a rail yard which provides train

classification, car switching, and locomotive re-fueling (CSX Transportation Inc. Moncrief Rail Yard) as

well as car repair, blasting, and painting (Fruit Growers Express Rail Yard). The rail yards contain a

common groundwater remediation system for chlorinated organic contaminants, polynuclear aromatic

hydrocarbons and volatile organic contaminants. The remediation system treats the contaminated

groundwater by air stripping from recovery wells. Treated wastewater is discharged through Outfall D001into McCoys Creek, which ultimately drains to Lower St Johns River.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 1.09 mg/L and 0.108 mg/L,

respectively, for the Trout River (Segment ID 1802) in the St. Johns River Estuary. However, there are no

effluent data from which to assess compliance, and the CSXT Moncrief Rail Yard and Fruit Growers

Express Yard does not have existing effluent limits or monitoring requirements for TN or TP. Given the

lack of existing permit requirements and that no discharges have been recorded in the past five years, it is

unlikely that this facility would have reasonable potential under the proposed rule. Thus, incremental

compliance costs are likely zero.
42

ExxonMobil Oil Corporation, Port Everglades North and South Terminals

NPDES permit number: FL0043460

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd for Outfall D-001 and 0.576 mgd for Outfall D-003

Average Flow: No discharges in the past five years

Receiving Water: Port Everglades Turning Basin, Intracoastal Waterway

Description

ExxonMobil Oil Corporation, Port Everglades North and South Terminals are bulk petroleum storage and

distribution facilities consisting of two separate north tank farm and south tank farm sites. The north tank

farm includes five main storage tanks for petroleum products (with a combined storage capacity of 9.2

MG); two smaller storage tanks for petroleum contact waters. The north tank farm is surrounded by an

unlined containment basin area. The south tank farm consists of four main storage tanks for petroleum

products (with a combined storage capacity of 12.2 MG) and two smaller storage tanks for petroleum

contact water. The south tank farm is surrounded by a lined containment basin area.

The north tank farm discharges hydrostatic tank test water and stormwater through Outfall D-001 to a

storm sewer that ultimately empties into Slip No. 1 at Port Everglades Turning Basin, which is contiguous

to the Intracoastal Waterway. Stormwater is usually disposed of via percolation with the containment

area, but may be discharged through D-001.

The south tank farm discharges hydrostatic tank test water and stormwater through Outfall D-003 to an

unnamed drainage ditch. From the unnamed drainage ditch, the discharge proceeds to the Eller Drive

ditch, thence to the FP&L cooling water discharge canal (which also receives effluent from Florida Power

and Light, Lauderdale Plant, FL0001538, and other NPDES permitted dischargers), which ultimately

discharges into the Intracoastal Waterway. If and oil sheen is present, an oil/water separator treats

stormwater from the diked areas, otherwise, this stormwater is discharged without treatment.

Both tank farms normally discharge hydrostatic test water without treatment, though the permit requires

analysis prior to discharge to ensure that effluent limitations are met. The facility collects petroleum

contact water, including tank bottom water and loading rack runoff, which is ultimately hauled offsite for

disposal.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

ExxonMobil Oil Corporation, Port Everglades North and South Terminals discharge to coastal waters, for

which EPA has proposed only chlorophyll-a criterion. While there are no TN and TP criteria, EPA

assumes that ExxonMobil Corporation would be required to meet the concentrations associated with

economically feasible treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for

exceeding the chlorophyll-a criterion. However, ExxonMobil Oil Corporation does not have effluent

limits or monitoring requirements for TN or TP at the Port Everglades North and South Terminals. Given

the lack of permit requirements and the nature of the wastewater (i.e., hydrostatic test water and

stormwater) and that no discharges have occurred in the past five years, it is unlikely that the facility
43

would have reasonable potential under the proposed rule. Thus, incremental compliance costs are likely

zero.
44

Florida Atlantic University Sea Tech Facility

NPDES permit number: FL0178870

Major/minor: Minor

SIC code: 8733 (Noncommercial Research Organizations)

Industrial Category: Other

Design Flow: 0.062 mgd

Average Flow: 0.054 mgd (average of maximum monthly values from 2006 through

2010)

Receiving Water: Whiskey Creek or New River Sound

Description

Florida Atlantic University Sea Tech Facility is a university research institute that engages in various

aspects of ocean engineering research activities. Part of the operation carried out at the facility involves

the study of marine materials and corrosion effect as relating to offshore structures using natural sea water

in holding tanks. Inside the tanks, sea water comes into contact with a variety of coupon-sized test

samples of metal (steel and aluminum), reinforced concrete, and carbon fiber composites structural

materials that are in suspension and submerged under water. Researches renew the test water in the tanks

periodically with new sea water to maintain general freshness and to prevent bio-growth inside the tanks.

Florida Atlantic University Sea Tech Facility periodically discharges "spent" test sea water through

Outfall D-001 to the south end of the Whiskey Creek or New River Sound. Note that only 5% to 10% of

the total sea water withdrawn is actually routed into the two test tanks. The majority of the inflow

bypasses the tanks entirely, and flows directly to the outfall. The facility does not treat the spent sea water

before discharge due to the historic low level of pollutants being introduced into the waste stream from

the test processes, absence of foreign chemical additives used in the study, high proportion of noncontact

direct bypass flow, and the very well controlled environment of the laboratory. The test tanks are

manually scrubbed down periodically to remove any larger settled and floating debris or excess biogrowth.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

Florida Atlantic University Sea Tech Facility discharges to coastal waters, for which EPA has proposed

only chlorophyll-a criterion. While there are no TN and TP criteria, EPA assumes that Florida Atlantic

University would be required to meet the concentrations associated with economically feasible treatment

(i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the chlorophyll-a

criterion. However, Florida Atlantic University Sea Tech Facility does not have effluent limits or

monitoring requirements for TN or TP at the Sea Tech Facility. Given the lack of permit requirements and

the nature of the wastewater (i.e., spent and noncontact sea water), it is unlikely that the facility would

have reasonable potential under the proposed rule. Thus, incremental compliance costs are likely zero.
45

Harbor Branch Oceanographic Institute at Florida Atlantic University

NPDES permit number: FL0139912

Major/minor: Minor

SIC code: 8733 (Noncommercial Research Organizations)

Industrial Category: Other

Design Flow: 0.014 mgd for I-002

Average Flow: 0.010 mgd for I-002 (average of average monthly values for 2006-2007)

Receiving Water: North Coast Wetlands to Indian River Lagoon

Description

The permit for the Harbor Branch Oceanographic Institute at Florida Atlantic University covers a RO

water treatment plant that provides drinking water for Harbor Branch Oceanographic Institute at the

Florida Atlantic University. Untreated RO concentrate is discharged through Internal Outfall I-002 into a

stormwater detention pond which also receives stormwater and onsite well water. Outfall D-001

discharges the combined diluted wastewaters from the stormwater detention pond to the adjacent North

Coast Wetlands and ultimately into the Indian River Lagoon.

Summary of Effluent Data and Limits

Average monthly effluent data for TP from 2006 to 2010 are available from EPA’s ICIS-NPDES

database. For TN, a laboratory report indicates that in 2005, TN concentrations were approximately 0.64

mg/L (FDEP, 2006a). There are no effluent limits for TN in the current permit. Exhibit 30 summarizes

these data.

Exhibit 30: Effluent Data Summary, Harbor Branch Oceanographic Institute at FAU

Pollutant Number of

Observations

Average Effluent

(mg/L)1 Permit Limit (mg/L)

Outfall D-001

TN 1 0.64 None

TP 39 0.68 None

Source: FDEP (2006a) for TN and EPA (2011) for TP.

1. TP effluent data represents average of maximum monthly values from 2006 through 2010.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 1.12 mg/L and 0.117 mg/L,

respectively, for the Lower Central Indian River Lagoon segment (Segment ID 1505) in the Indian River

Lagoon.

Although IWR data indicate that the segment is likely in compliance with the proposed criteria, no mixing

zone is described in the permit, so it is uncertain as to whether a mixing zone would be granted. EPA

conservatively (i.e., erring on the side of estimating greater impact and higher costs under the proposed

rule) assumes that the Institute would need to meet effluent limits based on criteria end-of-pipe (i.e., no

dilution). Exhibit 31 summarizes the RP analysis and estimated projected effluent limits for the facility.
46

Exhibit 31: Reasonable Potential Analysis, Harbor Branch Oceanographic Institute at FAU

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

(mg/L)

TN 0.64 0.66 1.12 No None

TP 0.68 0.072 0.117 Yes 0.117

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe because the existing permit does not provide dilution for effluent limits.

The exhibit indicates that the facility would not likely have RP under the proposed rule for TN because

the average effluent concentration is below the proposed criterion, and would not incur incremental

compliance costs.

However, the facility would likely have RP for TP based on average effluent concentrations. In addition,

the facility would not be in compliance with the projected effluent limit for TP and may need to

implement some incremental level of control. To meet the projected WQBEL, EPA estimates compliance

costs based on installation of chemical precipitation followed by filtration.

Capital and O&M unit costs associated with this treatment could be $0.32/gpd and $238/MG,

respectively. EPA assumes that treatment would be required only for the RO concentrate stream (Outfall

I-002), and not for the other wastewater components (e.g., stormwater and onsite well water). Based on a

design flow of 0.014 mgd, total capital costs could be approximately $4,500. During the last 5 years, the

average of average monthly flows has been approximately 0.010 mgd. Thus, assuming operation of the

treatment units 365 days per year, O&M costs could be approximately $900. Total annual costs would be

$1,300 based on annualizing capital costs at 7% over 20 years and adding annual O&M. Exhibit 32

summarizes these costs.

Exhibit 32: Potential Incremental Costs, Harbor Branch Oceanographic Institute at FAU

Treatment Controls Capital Costs

($)1

O&M Cost

($/year)2

Annual Costs

($/year)3

Chemical precipitation

with filtration $4,500 $900 $1,300

1. Design flow multiplied by unit cost of $0.32/gpd for chemical precipitation with filtration.

2. Average flow multiplied by unit cost of $238/MG for chemical precipitation with filtration and the number of

operating days per year (365 days).

3. Capital costs annualized at 7% over 20 years plus annual O&M.
47

Marathon Petroleum Company, Port Everglades Eisenhower Boulevard Terminal

NPDES permit number: FL0173975

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.75 mgd

Average Flow: 0.15 mgd (only one maximum monthly value from 2006 through 2010)

Receiving Water: Port Everglades Turning Basin

Description

Marathon Petroleum Company, Port Everglades Eisenhower Boulevard Terminal is a bulk petroleum

products storage and distribution facility consisting of 17 aboveground storage tanks. The 12 major tanks

(with capacities ranging from 0.7 to 3.5 MG) store various petroleum products including unleaded

gasoline and diesel fuel. A new ethanol storage tank is also under construction. The remaining 5 smaller

tanks (with capacities between 21,000 to 340,000 gallons) store fuel additives. There are also two tanks

(20,000 gallons each) for storing petroleum contact water and one tank (20,000 gallons) for “Transmix”

or pipeline intermixture storage. The tank farm is surrounded by gravel and earthen dikes in an unlined

basin.

Hydrostatic test water is discharged through Outfalls D-001 to an offsite storm sewer, which ultimately

discharges into the Port Everglades Turning Basin. Hydrostatic test water is normally discharged without

treatment, although the permit requires analysis prior to discharge to ensure that effluent limitations are

met. If necessary, portable water treatment equipment (e.g., diatomaceous earth filters) may be used to

reduce the particular pollutant(s) of concern. Oil/water separators treat petroleum contact water, which

includes tank bottom water and loading rack runoff. Treated petroleum contact is stored onsite and

ultimately hauled offsite for disposal. Recovered oil is stored in the Transmix tank. Stormwater is

normally disposed of by percolation and evaporation, however, stormwater discharge is allowed by a

separate Multi-Sector Generic Permit.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

Marathon Petroleum Company, Port Everglades Eisenhower Boulevard Terminal discharges to coastal

waters, for which EPA has proposed only chlorophyll-a criterion. While there are no TN and TP criteria,

EPA assumes that Marathon Petroleum Company would be required to meet the concentrations associated

with economically feasible treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for

exceeding the chlorophyll-a criterion. However, Marathon Petroleum Company does not have effluent

limits or monitoring requirements for TN or TP at the Port Everglades Eisenhower Boulevard Terminal.

Given the lack of permit requirements and the nature of the wastewater (i.e., hydrostatic test water), it is

unlikely that the facility would have reasonable potential under the proposed rule. Thus, incremental

compliance costs are likely zero.
48

Marathon Petroleum Company, Port Everglades Spangler Boulevard Terminal

NPDES permit number: FL0000582

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd

Average Flow: Intermittent, 0.48 mgd (average of maximum monthly values from 2006

through 2011)

Receiving Water: Port Everglades Turning Basin

Description

Marathon Petroleum Company, Port Everglades Spangler Boulevard Terminal is a bulk petroleum storage

and distribution facility. This facility has five major storage tanks (2.1 to 5.0 MG capacities) for unleaded

gasoline, fuel and fuel additives, and several smaller tanks for storing ethanol (six 30,000 gallon tanks)

and petroleum contact water (four 30,000 gallon tanks). The tank farm is surrounded by earthen dikes in

an unlined basin, which includes three stormwater detention ponds.

Marathon Petroleum Company discharges hydrostatic tank test water from the terminal through Outfall

D-001 into a storm sewer that empties into the Port Everglades Turning Basin. Normally, this discharge is

not treated, although the permit requires analysis prior to discharge to ensure that effluent limitations are

met. Oil/water separators treat petroleum contact water, which includes tank bottom water and loading

rack runoff. Treated petroleum contact is stored onsite and ultimately hauled offsite for disposal.

Stormwater discharge is covered under a Multi-Sector Generic Permit.

Summary of Effluent Data and Limits

TN and TP data are not available from EPA’s ICIS-NPDES database. However, a laboratory report

indicates that in 2002, TP concentrations were approximately 0.068 mg/L and total Kjeldahl nitrogen

concentrations were approximately 0.88 mg/L (FDEP, 2002). TN data are not available for this facility,

however total Kjeldahl nitrogen is the sum of organic nitrogen, and ammonia and ammonium as nitrogen,

and can be used to estimate TN by adding the concentrations of nitrate and nitrite as nitrogen. Nitrate and

nitrite data are not available for this facility, however, laboratory reports from two other Florida NPDES

permitted facilities in SIC code 5171: Petroleum Bulk Stations and Terminals report insignificant

amounts of nitrate and nitrite.2 Thus, EPA used total Kjeldahl nitrogen levels as a proxy for TN for this

analysis. There are no effluent limits for TN and TP in the current permit. Exhibit 33 summarizes these

data.

Exhibit 33: Effluent Data Summary, Marathon Petroleum Company, Port Everglades Spangler

Boulevard Terminal

Pollutant Number of

Observations

Average Effluent

(mg/L) Permit Limit (mg/L)2

TN11 0.88 None

TP 1 0.068 None

Source: FDEP (2005a)

1. Represents sum of total Kjeldahl nitrogen and nitrate plus nitrite.

2 Nitrate and nitrite as nitrogen concentrations were approximately 0.088 mg/L in 2004 for FL0035149 (FDEP, 2005a) and 0.006

mg/L in 2008 for FL0035921 (FDEP, 2009b).
49

Potential Incremental Impacts

Marathon Petroleum Company, Port Everglades Spangler Boulevard Terminal discharges to coastal

waters, for which EPA has proposed only chlorophyll-a criterion. While there are no TN and TP criteria,

EPA assumes that the facility would be required to meet the concentrations associated with economically

feasible treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the

chlorophyll-a criterion. The 2002 discharge report suggests that effluent concentrations likely attain these

levels. Therefore, incremental compliance costs are unlikely.
50

Marine Park of Flagler

NPDES permit number: FL0526533

Major/minor: Minor

SIC code: 8422 (Arboreta and Botanical or Zoological Gardens)

Industrial Category: Other

Design Flow: 8.64 mgd

Average Flow: 1.89 mgd (average of average monthly values from 2008 through 2011)

Receiving Water: Intercostal Waterway

Description

Marine Park of Flagler is a 1.3 million gallon human-dolphin interaction habitat for dolphin research and

tourism. Ocean water from the Atlantic Ocean is treated by sand filters to remove turbidity and improve

clarity. A portion of the incoming ocean water receives additional treatment using ozone for disinfection

and fractionators to remove particulate matter and oxidized proteins. The combined water is treated with

sodium hypochlorite before entering the dolphin habitat. A portion of the habitat water is treated with

lanthanum for algae control and recirculated through the sand filters.

Wastewaters from the habitat and filter backwash water are treated with sodium thiosulfate for

dechlorination. The treated wastewaters are discharged to an onsite lagoon, which is connected to the

Intracoastal Waterway via outfall pipes.

Summary of Effluent Data and Limits

Exhibit 34 summarizes average quarterly effluent data for TN from 2008 to 2011. TP data were not

available in EPA’s ICIS-NPDES database or from laboratory reports for this discharger.

Exhibit 34: Effluent Data Summary, Marine Park of Flagler

Pollutant Number of

Observations

Average Effluent

(mg/L)1 Permit Limit (mg/L)

TN 12 0.58 None

Source: EPA (2011)

1. TP effluent data from 2008 through 2011. Represents average of maximum monthly values.

Potential Incremental Impacts

EPA is proposing annual geometric mean criteria for TN and TP of 0.53 mg/L and 0.108 mg/L,

respectively, for the Matanzas River segment (Segment ID 1702) of the Intercostal Waterway in the

Guana-Tolomato-Matanzas Estuary.

Analysis of FDEP’s IWR data indicate that the segment is not likely in compliance with the proposed TN

criterion under the proposed rule but could be in compliance with the proposed TP criterion. However,

because the existing permit does not describe a mixing zone for calculation of other pollutant limits, EPA

conservatively (i.e., erring on the side of estimating greater impact and higher costs under the proposed

rule) assumes the discharger would not receive a mixing zone under the proposed rule. Exhibit 35

summarizes the RP analysis and estimated projected effluent limits for the facility.
51

Exhibit 35: Reasonable Potential Analysis, Marine Park of Flagler

Pollutant Average Effluent

Concentration

(mg/L)

Maximum Ambient

Geometric Mean1

(mg/L)

Proposed

Criterion2

(mg/L)

Reasonable

Potential

Projected

WQBEL3

TN 0.58 0.64 0.53 Yes 0.53

TP Not available 0.083 0.108 Uncertain Not applicable

1. Represents maximum annual geometric mean for the segment from FDEP’s IWR database.

2. Proposed annual geometric mean criterion.

3. Represents criterion end-of-pipe even though ambient data indicate that the segment may be in compliance with

the proposed criteria because the existing permit does not provide dilution for effluent limits.

The exhibit indicates that the facility would likely have RP under the proposed rule for TN because the

average effluent concentration exceeds the proposed criterion. Based on average effluent concentrations,

the facility would not be in compliance with the projected effluent limit for TN and may need to

implement some incremental level of control. However, due to the extremely low TN criterion, there is

significant uncertainty as to whether the projected effluent limits are technologically or economically

feasible to attain. Thus, EPA estimates costs based on the assumption of a variance from meeting effluent

limits based on criteria end-of-pipe. Since current effluent TN levels are already below the concentration

associated with economically feasible nitrogen treatment (i.e., 3 mg/L for TN), incremental compliance

costs associated with TN are also unlikely.

For TP, there are no effluent data from which to assess compliance, and the Marine Park of Flagler does

not have existing effluent limits or monitoring requirements for TP. Given the lack of existing permit

requirements, existing treatment, and the nature of the wastewater (e.g., treated ocean water), it is unlikely

that the Park would have reasonable potential under the proposed rule. Thus, incremental compliance

costs are likely zero.
52

Motiva Enterprises LLC, Port Everglades East Terminal

NPDES permit number: FL0035351

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd

Average Flow: No discharges in the past five years

Receiving Water: Intracoastal Waterway

Description

Motiva Enterprises LLC, Port Everglades East Terminal is a bulk petroleum storage and distribution

facility consisting of 15 main aboveground tanks (with capacities of 0.44 to 3.3 MG) storing aviation

gasoline, jet fuel, and diesel. In addition, the facility has two smaller tanks (10,000 and 20,000 gallons)

for storing petroleum contact waters. The 15-acre site includes five acres of impervious area (office

building and truck loading rack operation) and 10 acres of unlined pervious basin areas that comprise

three secondary containment cells.

Hydrostatic tank test water and stormwater from the facility are discharged through Outfall D-001 to the

Florida Power and Light cooling water discharge canal (which also receives effluent from Florida Power

and Light, Lauderdale Plant, FL0001538, and other NPDES permitted dischargers), which ultimately

discharges into the Intracoastal Waterway. Hydrostatic test water is normally discharged without

treatment, although the permit requires analysis prior to discharge to ensure that effluent limitations are

met. Stormwater runoff from outside of the roofed loading rack perimeter the impervious area is pumped

to the pervious diked area. Disposal of runoff and stormwater collected within the diked area is normally

by percolation and evaporation, any excess stormwater drained across the three secondary containment

cells and eventually to the outfall. Oil/water separators treat petroleum contact water, which includes

runoff from within the loading rack perimeter and tank bottom water. Treated petroleum contact is stored

onsite and ultimately hauled offsite for disposal.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

Motiva Enterprises LLC, Port Everglades East Terminal discharges to coastal waters, for which EPA has

proposed only chlorophyll-a criterion. While there are no TN and TP criteria, EPA assumes that Motiva

Enterprises LLC would be required to meet the concentrations associated with economically feasible

treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the chlorophylla criterion. However, Motiva Enterprises LLC does not have effluent limits or monitoring requirements

for TN or TP at the Port Everglades East Terminal. Given the lack of permit requirements, the nature of

the wastewater (i.e., hydrostatic test water and stormwater) and that no discharges have occurred in the

past five years, it is unlikely that the terminal would have reasonable potential under the proposed rule.

Thus, incremental compliance costs are likely zero.
53

Motiva Enterprises LLC, Port Everglades South Terminal

NPDES permit number: FL0167720

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd

Average Flow: 0.41 mgd (only one maximum monthly value from 2006 through 2010)

Receiving Water: Intracoastal Waterway

Description

Motiva Enterprises LLC, Port Everglades South Terminal is a bulk petroleum storage and distribution

facility consisting of 9 aboveground tanks (with capacities of 1.80 to 4.06 MG) storing unleaded gasoline,

super unleaded gasoline, aviation jet fuel, diesel and ethanol, and two smaller tanks (30,000 gallon) for

storing petroleum contact water, and a tank for storing chemical additives (30,000 gallon). The tank farm

is surrounded by earthen dikes in an unlined basin.

Hydrostatic tank test water and stormwater are discharged through Outfall D-001 to an unnamed drainage

ditch. From the unnamed drainage ditch, the discharge proceeds to the Eller Drive ditch, and then to the

Florida Power and Light cooling water discharge canal (which also receives effluent from Florida Power

and Light, Lauderdale Plant, FL0001538, and other NPDES permitted dischargers), which ultimately

discharges into the Intracoastal Waterway. Hydrostatic test water is normally discharged without

treatment, although the permit requires analysis prior to discharge to ensure that effluent limitations are

met. Disposal of stormwater is normally by percolation and evaporation. However, stormwater may be

discharged through Outfall D-001 if no oil sheen is present. Oil/water separators treat petroleum contact

water, which includes tank bottom water and loading rack runoff. Treated petroleum contact is stored

onsite and ultimately hauled offsite for disposal.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

Motiva Enterprises LLC, Port Everglades South Terminal discharges to coastal waters, for which EPA

has proposed only chlorophyll-a criterion. While there are no TN and TP criteria, EPA assumes that

Motiva Enterprises LLC would be required to meet the concentrations associated with economically

feasible treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the

chlorophyll-a criterion. However, the Motiva Enterprises LLC does not have effluent limits or monitoring

requirements for TN or TP from the Port Everglades South Terminal. Given the lack of permit

requirements and the nature of the wastewater (i.e., hydrostatic test water and stormwater), it is unlikely

that the facility would have reasonable potential under the proposed rule. Thus, incremental compliance

costs are likely zero.
54

TPSI Terminals LLC, Port Everglades Bulk Terminal

NPDES permit number: FL0022543

Major/minor: Minor

SIC code: 5171 (Petroleum Bulk Stations and Terminals)

Industrial Category: Other

Design Flow: 0.5 mgd for Outfall D-003 and 0.5 mgd for Outfall D-004

Average Flow: Intermittent, 0.43 mgd for Outfall D-003 (average of maximum monthly

values from 2006 through 2011); no discharges in the past five years for

Outfall D-004

Receiving Water: Intracoastal Waterway

Description

TPSI Terminals LLC, Port Everglades Bulk Terminal is a bulk petroleum storage and distribution facility

at Port Everglades with 11 major aboveground tanks (1.4 to 2.7 MG capacities) for storing unleaded

gasoline and diesel fuels. In addition, the terminal has a 40,000 gallon tank for storing petroleum contact

water. The tank farm is surrounded by earthen dikes in an unlined basin. TransMontaigne Partners LP is

the owner of this facility and another SIC 5171 (Petroleum Bulk Stations and Terminals) facility in Port

Everglades, Coastal Terminals, Port Everglades Terminal (FL0039969), which is located north of this

facility.

Hydrostatic test water from the terminal is discharged through Outfalls D-003 and D-004 to the Florida

Power and Light cooling water discharge canal (which also receives effluent from Florida Power and

Light, Lauderdale Plant, FL0001538, and other NPDES permitted dischargers), which ultimately

discharges into the Intracoastal Waterway. Hydrostatic test water is normally discharged untreated,

although the permit requires analysis prior to discharge to ensure that effluent limitations are met.

Oil/water separators treat petroleum contact water, which includes tank bottom water and loading rack

runoff. Treated petroleum contact is stored onsite and ultimately hauled offsite for disposal. Stormwater

discharge is covered by a separate Multi-Sector Generic Permit.

Summary of Effluent Data and Limits

There are no effluent TN and TP data available in EPA’s ICIS-NPDES database for this discharger.

Potential Incremental Impacts

TPSI Terminals LLC, Port Everglades Bulk Terminal discharges to coastal waters, for which EPA has

proposed only chlorophyll-a criterion. While there are no TN and TP criteria, EPA assumes that Florida

Power and Light would be required to meet the concentrations associated with economically feasible

treatment (i.e., 3 mg/L for TN and 0.1 mg/L for TP) to reduce the potential for exceeding the chlorophylla criterion. However, Florida Power and Light does not have effluent limits or monitoring requirements

for TN or TP at the Lauderdale Plant. Given the lack of permit requirements and the nature of the

wastewater (i.e., hydrostatic test water), it is unlikely that plant would have reasonable potential under the

proposed rule. Thus, incremental compliance costs are likely zero.
55

References

Busby, T. Wildwood Consulting. 2009. Personal communication. August.

Carollo Engineers. 2009. “Technologies to Meet Numeric Nutrient Criteria at Florida’s Domestic Water

Reclamation Facilities.” Letter to Governor Charlie Crist Re: Numeric Nutrient Criteria Cost

Implications for Florida POTWs. Dated December 3, 2009.

Florida Department of Environmental Protection (FDEP). 2002. Bioassays of Motiva Enterprises LLC –

Port Everglades North Terminal (FL0000582). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/1678.pdf

Florida Department of Environmental Protection (FDEP). 2004a. Bioassays of Florida Power Corporation

Crystal River (FL0036366). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/3501.pdf

Florida Department of Environmental Protection (FDEP). 2004b. Bioassays of Vero Beach Municipal

Power Plant (FL0002984). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/3064.pdf

Florida Department of Environmental Protection (FDEP). 2004c. Fact Sheet for Florida Department of

Environmental Production Industrial Wastewater Facility Permit, Florida Power & Light Company

Turkey Point Power Plant (FL0001562).

Florida Department of Environmental Protection (FDEP). 2005a. Bioassays of MacDill Air Force Base

Defense Fuel Support Point Industrial WWTF (FL0035149).

ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/5182.pdf

Florida Department of Environmental Protection (FDEP). 2005b. Bioassays of Tampa Electric CompanyBayside (FL0000809). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/5963.pdf

Florida Department of Environmental Protection (FDEP). 2006a. Bioassays of Harbor Branch

Oceanographic Institute Reverse Osmosis Concentrate Disposal Facility (FL0139912).

ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/6381.pdf

Florida Department of Environmental Protection (FDEP). 2006b. Bioassays of the City of Homestead

Municipal Power Plant (FL0002721). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/6463.pdf

Florida Department of Environmental Protection (FDEP). 2006c. Industrial Wastewater Facility Permit,

Port Sutton Ammonia Terminal (FL0038652).

Florida Department of Environmental Protection (FDEP). 2008a. Effluent Quality Assessment, Florida

Power and Light Company, Fort Myers Plant (FL0001490).

ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/9402.pdf

Florida Department of Environmental Protection (FDEP). 2008b. Effluent Quality Assessment, Florida

Power and Light Lauderdale Plant (FL0001503). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/8105.pdf

Florida Department of Environmental Protection (FDEP). 2008c. Effluent Quality Assessment, FPL Port

Everglades Plant (FL0001538). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/8104.pdf

Florida Department of Environmental Protection (FDEP). 2008d. Effluent Quality Assessment,

Trademark Nitrogen Corporation (FL0000647). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/9106.pdf

Florida Department of Environmental Protection (FDEP). 2009a. Effluent Quality Assessment, Anclote

Power Plant (FL0002992). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/9763.pdf

Florida Department of Environmental Protection (FDEP). 2009b. Effluent Quality Assessment, Chevron

Port Tampa Terminal (FL0035921). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/9521.pdf
56

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Morgan Ammonia Facility (FL0000264). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/9482.pdf

Florida Department of Environmental Protection (FDEP). 2009d. Effluent Quality Assessment, Jefferson

Smurfit Corporation, Fernandina Beach Mill (FL0001104).

ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/9686.pdf

Florida Department of Environmental Protection (FDEP). 2009e. Effluent Quality Assessment, Tampa

Electric Company Big Bend Power Station (FL0000817).

ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/9761.pdf

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Industrial Wastewater Treatment Pond System Wastewater and Other Treatments Systems from

Installation of Units 3 - 6. Tampa Electric Company, Bayside Power Station (FL0000809).

Florida Department of Environmental Protection (FDEP). 2010a. Effluent Quality Assessment, Florida

Power and Light Company St. Lucie Plant (FL0002208).

ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/10181.pdf

Florida Department of Environmental Protection (FDEP). 2010b. Effluent Quality Assessment, Progress

Energy Florida Crystal River Plant Units 1, 2 and 3 (FL0000159).

ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/9904.pdf

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Power Company – Lansing Smith Power Plant (FL0002267).

ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/11146.pdf

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Performance Fibers, LLC (FL0000701). ftp://ftp.dep.state.fl.us/pub/labs/lds/reports/1081.pdf

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57

Appendix: Alternative Treatment Scenario

EPA projected extremely low WQBELs for five dischargers that may not be feasible to attain. Thus, EPA

estimated costs based on a scenario in which the dischargers pursue a variance from WQS. Actual revised

WQBELs may differ from those estimated by EPA, and dischargers may pursue alternative compliance

methods. Exhibit 36 provides the estimated costs of a scenario in which the dischargers install RO to

meet revised effluent limits, based on the unit costs presented in the economic analysis accompanying the

proposed rule [capital costs and O&M costs for RO with microfiltration of $8.10/gpd and $3,000/MG,

respectively, including residual disposal via a brine concentrator, based on Carollo Engineers (2009)].

Exhibit 36: Estimated Potential Cost of Reverse Osmosis to Meet Extremely Low Nutrient Effluent

Limits

Facility Name

Projected Effluent

Limits (mg/L) Flow (mgd)1 Discharge

Days2

Reverse Osmosis Costs

($ millions)

TN TP Design Average Capital O&M Annual3

Gulf Power Company,

Lansing Smith Power 0.22 0.014 5.01 4.36 365 $40.6 $4.8 $8.6

Progress Energy, Crystal

River Units 1, 2, and 3 0.36 0.013 0.085 0.081 365 $0.7 $0.1 $0.2

Rayonier Performance

Fibers, LLC 0.27 0.045 26.3 16.8 365 $213.1 $18.4 $38.5

Smurfit Stone,

Ferndandina Beach Mill 0.27 0.045 37.5 17.1 365 $303.8 $18.7 $47.4

Marine Park of Flagler 0.53 NA 8.64 1.89 365 $70.0 $2.1 $8.7

Total NA NA NA NA NA $628.2 $44.1 $103.4

NA = not applicable

1. See individual facility analyses above for explanation of design and average flows.

2. See individual facility analyses above for explanation of discharge days

3. Represents capital costs annualized at 7% over 20 years plus annual O&M costs.

Compared to the compliance scenario reflective of a variance from WQS, the incremental estimated

annual costs under a scenario of RO treatment under the proposed criteria, total industrial costs would

increase by approximately $88.2 million annually.