Notes from Site Visit at Florida Power and Light’s Manatee Power Plant on November 16, 2011

EPA conducted a site visit at Florida Power and Light’s (FP&L’s) Manatee Power Plant ( Manatee ) located in Parrish , FL on Wednesday, November 16 , 20 11 to learn about the operations at the plant , specifically waste streams associated with ash handling operations for the oil

- fired units (Units 1 and 2)

. Table 1, located at the end of th ese notes, ide ntifies the site visit participants. The presentation given by the Manatee personnel during the site visit is provided as Attachment 1.

Th ese notes describe the information collected during the site visit and the pre

- site visit phone call, which was held on November 1, 20 11

. For completeness , some information provided in the plant’s response to EPA’s Questionnaire for the Steam Electric Power Generating Effluent Guidelines (referred to as the EPA survey) is included

.

Plant Overview

• The Manatee plant com prises 9,820 about 9,500 acres and typically employs about xx 100 people.

[ QUESTION FOR MANATEE: Please confirm the site acreage, taken from the EPA survey response, and the number of employees.]

• Manatee began operations in 1976 when Unit 1 began operating. Units 1 and 2 were both oil

- fired units and were later converted to dual

- fuel units in 2005 2003 to provide fuel diversification

. Unit 3, a combined cycle gas

- fired unit, was also added in 2005.

• FPL has retained the capability to burn oil for fuel diversification during normal operations, to serve as a fuel source should natural gas be unavailable, and to enable the units to generate peak power. For example, Units 1 and 2 can generate up to 500 M W on natural gas, but FPL must also burn oil to generate greater amounts of electricity from these units (i.e., up to maximum generating capacity of approximately 800 MW each)

• Manatee currently operates three electric generating units at the power plant, with a gross generating capacity (generator design nameplate values of 2, 400 2,951 MW

. The table below contains some general information for the three generating units.

Unit Installation Date Gross Capacity (MW) Capacity Factor Fuel Type NOx Control 1 1976 8 63 20

- 25% #6 Fuel Oil and/or Natural Gas Low NOx burner Reburn Technology 2 1977 8 63 20

- 25% #6 Fuel Oil and/or Natural Gas Low NOx burner

Reburn technology 3 2005 472 (steam turbine) 70% Natural Gas

– DLN 2.6Page 2

753 (4 combustion turbines ) Combined Cycle (Dry Low NOx combustion tuning) [ QUESTION FOR MANATEE: Please confirm the plant gross generating capacity, as the survey response was 2,951 MW. Also, please confirm the installation dates for the units and the gross capacity of the steam vs combustion turbines for Unit 3. Information highlighted above was obtained from the survey response or EIA.]

Unit 1 and Unit 2 Operations

• Unit s 1 and 2 burn either #6 distil lat e fuel oil or natural gas, primarily depending on the current market price.

• The plant has decreased the amount of oil burned annually over the last several years. Currently, oil

- fired steam generation reflects about 10

- 15% of the electricity generated by the plant . The oil ha s an average ash content of 0.05 percent and an a verage sulfur content of about x x 1.0 percent.

[ QUESTION FOR MANATEE: Please provide average sulfur content of No. 6 distillate fuel oil used.]

• When Unit 1 or 2 is operating, the fly ash is collected daily through the

e conomizer h opper s , dust collectors

, and a ir p reheater hoppers

. Fly a sh drops out of the economizer hopper s into the ash sluice pipe, where it is gravity fed to the ash pit. Fly a sh is also sluiced from the dust collectors and air preheater hoppers. On average, about 0.35 million gallons of sluice water is used per month.

• Sluice water is obtained from the plant service water tanks as needed to run the sluicing system

.

• Bottom ash is manually removed from the units during normal outage periods. The bottom ash is then containerized and dispos ed off site. Wash water from the cleaning of the unit is transferred to the ash pit.

• The ash pit is about 10 feet deep, 10 feet wide, and 18 feet long. Pumps transfer the water to the ash basins based on the level of wastewater in the pit.

Planned Conve rsion for Unit 2

.

• Manatee is replacing the dust collectors on Unit 2 with an electrostatic precipitator (ESP) in response to air regulations. The ESP is designed for full operation of the unit burning oil, and is expected to collect 90% of the ash generated by the unit. Construction bega n in October 2011 and is expected to be complete in May 2012.

• Because oil ash is stickier than coal ash, FP&L has designed the ESP to continuously pull ash fro m the hopper, rather than letting it build up in the hopper before removal.Page 3

• Ash from the ESP will be stored in a carbon steel storage silo, located at one end of the site near Units 1 and 2. Ash will be transferred up to 500 feet to the storage silo. FP& L has designed the silo to store up to one week’s worth of ash for both Units 1 and 2, if needed.

• Ash from the storage silo is moisture conditioned in a pug mill, prior to transport and disposal off site.

[ QUESTION FOR MANATEE: Can FP&L say whether this ash will be disposed to the same location as the current ash basin ash, and whether the disposal costs are expected to change?] ESP ash will be disposed in the same landfill as currently pressed ash. The cost should be less for ESP ash than the press ed ash due to a lower water content and therefore lower weight. We don’t have exact information at this time.

• FP&L is considering will be installing ESPs at Manatee Unit 1 and Martin Units 1 and 2.

Wastewater Treatment

• A water flow diagram of the plan t , provided in their response to the EPA survey, is included as Attachment 2

.

• Low volume waste, including equipment area drains, is transported to the two low volume wastewater basins, wh ere the water is held prior to transfer to the cooling water pond.

• Stormwater (both contact and noncontact) is transferred to the stormwater basin, which is concrete lined. The stormwater is treated through an oil/water separator, prior to being combined with other low volume and treated metal cleaning waste and discharg e to the cooling water pond. The plant monitors the discharge to the pond for pH, iron , copper, and oil and grease , total suspended solids, specific conductance, zinc, barium, cadmium, chromium, lead mercury, selenium, and arsenic

.

• Ash pit water from either Unit 1 or 2 , which includes ash sluice and m etal cleaning waste water , is transported to one of two concrete lined basin s. The basin includes two four mixers for aeration

. The pH of the incoming wastewater is pH 2

- 3 , but the plant has not monitored any other characteristics of the ash pit
wastewater . S odium hydroxide is added to elevate the pH , which may result in the precipitat ion of some metals. Aeration is ceased and the ash is allowed to settle out, prior to transferring the w ater to Outfall 004 (discharge to cooling water pond)

.

• Ash is removed from the basins when not in service. Ash is pressed using a portable press that services multiple FP&L plants, prior to transport and disposal off site. FP&L currently pays $ 35

- 50 per t on of ash for disposal in an off

- site waste management landfill.Page 4

[ QUESTION FOR MANATEE: Please confirm that the plant does not raise the pH above 9 S

. U

. , and confirm when chemical addition occurs

– before or after settling.] pH of the basin is raised to facilitate co

- precipitation and may occasionally exceed 9.0 SU , however pH cannot exceed 9.0 SU when combined with other waste streams and discharge via OSN 004.

• T he basins are lined with concrete

. and h igh density polyethylene (HPDE) with a thickness of 80 mils or 0.08 cm

.

• The cooling water pond is not lined and has a depth of about 15 feet and a “normal” volume of xxx 11.7 billion gallons. Once per year, Manatee staff test the spillway, which allows some discharge to the Little Manatee River.

[ QUESTION FOR MANATEE: Please provide the volume of the cooling water pond .]

• The survey response for Manatee shows a 3.84 MGD discharge from the cooling water pond to the Little Manatee River. However, this value was based on a one time emergency discharge in 2005, and normally the discharge is only 1 5 ,000

– 2 10 ,000 gallons per year during the permitted gate test

.Page 5

Table 1. Site Visit Attendees

Name Organization (Representing) Telephone E

- mail
Mary Maxwell FP&L Manatee Plant 941

- 7 76

- 5 27 8 Mary

. Maxwell @FPL.com

Paul Callahan FP&L Manatee Plant 941

- 776

- 5215 Paul. Callahan@FPL.com

Adam Richardson FP&L Manatee Plant 941

- 776

- 5265 Adam

. Richardson @FPL.com

Ron Hix Florida Power and Light 561

- 691

- 7641 Ron.Hix@FPL.com

Christian Kiernan Florida Power and Light 561

- 691

- 2781 Christian.kiernan@FPL.com

Eric Shea Florida Power and Light 561

- 691

- 2993 Eric.m.shea@FPL.com

Matthew Wetmore Florida Power and Light 561

- 691

- 2171 Matthew.Wetmore@FPL.com

Ron Jordan EPA/Office of Water 202

- 566

- 1003 jordan.ronald@epa.gov

Deb Bartram ERG (Contractor to EPA) 703

- 633

- 1669 deborah.bartram@erg.com