Draft Notes from Site Visit at Florida Pow er and Light’s Sanford Power Plant on October 7, 2009

EPA conducted a site visit at Florida Power and Light’s (FP&L’s) Sanford Power Plant (Sanford) located in Debary, FL on Wednesday, October 7, 2009 to learn a bout the operations at the plant, specifically the waste streams associat ed with the oil-fired units and the combined cycle units. Table 1, located at the end of this me morandum, identifies the site visit participants. The presentation that the Sanford personnel gave during the site vi sit is provided as Attachment

1 to this memorandum.

This memorandum describes the information collected during the site visit and the pre-site visit phone call, which was held on October 1, 2009.

Plant Overview

 The Sanford plant comprises 1,718 acres and currently employs 70 people. [QUESTION FOR SANFORD: How many people are employed by the plant?]

RESPONSE: No change.

 Sanford began operations in 1925 when Un its 1 and 2 began operating. Units 1

and 2 were both oil-fired un its and were retired in 1964.

 Sanford currently operates thre e electric generating units at the power plant, with a gross generating capacity of 2,156 MW [NOTE TO SANFORD: Please confirm total gross capacity.]. The table below contains some general information for the three generating units.

Unit Installation Date Gross Capacity (MW) Fuel Type NOx

Control

3 1958 156 #6 Fuel Oil and/or

Natural Gas None

4 1972 Repowered in 2003 320 (steam turbine) 680 (4 combustion turbines) Natural Gas – Combined Cycle DLN 2.6 (Dry Low

NOx

combustion tuning)

5 1973 Repowered in 2002 320 (steam turbine) 680 (4 combustion turbines Natural Gas – Combined Cycle DLN 2.6 (Dry Low

NOx

combustion tuning Note: Total gross generation is less than nameplate capacity due to steam generation limitations from the Heat Recovery Steam Generators. Values shown are from Title V Air Operating Permit.

[QUESTION FOR SANFORD: Please pr ovide any missing information.]Page 2

Unit 3 Operations

 Unit 3 was placed in an extended shut dow n in October 2008. If Sanford chooses to bring Unit 3 back online, it would lik ely be within 30 days; however, the unit can be restarted as quic k as 7 days, if needed.

 Unit 3 burns either #6 distillate fuel oil or natural gas, primarily depending on the current market price.

 The plant burned 2.5 million barrels of o il annually when Unit 3 was in operation. The oil had an average ash content of 0.05-0.06 percent and an average sulfur content of about 1 percent.

 When Unit 3 is operating, the ash is collected daily through the economizer hopper, air preheater washes, and boiler washes, and transferred to the ash treatment system once per day.

 Air preheater wash cycles are based on di fferential pressure. The washes typically occur approximately once every two weeks if the unit is operating at full load. The plant initially uses clean water to wash the air preheater. If pH is <4, soda ash is added. Wash volumes are approximately 25,000-30,000 gallons per wash. The air preheater wash water is piped to an above-ground concrete collection basin, then it is pumped to the ash basin (a lined basin).

 Approximately 1,000-1,500 gallons are gene rated during each economizer wash cycle.

 The boiler fireside washes occur during maintenance overhauls if the unit is exhibiting difficulty maintaining steam temperature. When unit 3 was in operation, the boiler fireside wa sh would occur once per year.

 FP&L staff indicated that conventional plan ts burning #6 fuel oil, such as FP&L’s Manatee, Martin, and Turkey Point plants, t ypically sluice the ash to an ash basin. For units where gas is primarily burned, a ny ash associated with oil burning is not collected separately but is emitted through the stack.

[NOTE TO SANFORD: Please provide ash sluice flow rates for the Manatee, Martin, and Turkey Point plants.]

RESPONSE: Ash sluice flow rates for Ma natee, Martin, and Turkey Point have been provided to the Agency via each facility’s response to EPA Questionnaire for the Steam Electric Power Generating Effluent Guidelines document.

 Unit 3 has once-through cooling water supplied by the St. John’s River.

 Unit 3 is operated as a p eaking unit, supplying electricity primarily in the summer

months.Page 3

Combined Cycle Unit Operations (Units 4 and 5)

 Units 4 and 5 originally were fueled by oil and natural gas. These units were repowered in 2002 and 2003 (i.e., convert ed into combined cycle units).

 Each unit has four combusti on turbines and one steam turbine. During the site visit, both units were operating with 3 combustion turbines and one steam turbine (“3-on-1”). Enough steam is generated from two of the combustion turbines to run the steam turbine, so the plant can operate in 2-, 3-, or 4-on-1 mode.

 The units are provided cooling wate r from a 1,100-acre cooling pond built

between 1970 and 1971. Water is recirculat ed from the pond to the units. Makeup water to the cooling pond comes from th e St. John’s River. The pond is not lined, but has engineered embankment wall s constructed with soil-cement. [NOTE TO SANFORD: How much cooling water is sent from Units 4 and 5 to the wet surface air coolers, and ultimately returned to the cooling pond?]

RESPONSE: Each power block wet su rface air cooler under normal operating conditions typically returns 50gpm back to the cooling pond. Inlet flow to each wet surface air cooler is based upon a nom inal level in the cooler basin and fluctuates based upon evaporation / drift ra te. Actual gpm flow rate to each

cooler is not recorded.

 The efficiency of Units 4 and 5 decreas es as the combustion turbine blades become dirty. Two types of water washes may be performed:

 On-line water washes occur every other day on these baseload units. Demineralized water is injected at the front end of the air compressor while the unit is operatin g for approximately five minutes and evaporates. There is no discharge from this operation.

 Off-line water washes of the air compressor are used to remove deposits using demineralized water and a low sudsing detergent. These washes tend to occur quarterly (or more fre quently in summer) and generate about 3,000 gallons of wastewater, which is sent to the low volume wastewater basins. The plant has conducted a TC LP analysis of the wastewater. [NOTE TO SANFORD: Please prov ide a copy of the analysis.]

RESPONSE: Separate attachment - FPL Sanford 5C Analysis.pdf

Wastewater Treatment

 A water flow diagram of the plan t is included as Attachment 2.

 Low volume waste, including equipment area drains and stormwater, is transported to the low volume wastewater basins, which consists of two basins, followed by an oil/water separator, pr ior to discharge to the cooling pond discharge canal. The plant monitors th e discharge to the canal for TSS and oil and grease.Page 4

 Metal cleaning waste, including turbine clean ing wash water, is transported to a lined basin, where precipitation chemicals ar e added and the water is retained for

24 hours. The basin includes two mixers. Th e pH is then adjusted to between 6 and 9 S.U., and then discharged to the cooling pond discharge canal over a period of about 3 days. [NOTE TO SANFORD: Please confirm if metal cleaning waste only comes from Unit 3, or also Units 4 and 5. Also, pl ease specify the precipitation chemicals added.]

RESPONSE: Unit 3 metal cleaning wastew ater is sent to the metal cleaning waste basin. Sodium hydroxi de is added to elevate the pH and precipitate out any metals. Once precipitation has occurred, the water is drawn from the basin and sent to an adjustment tank where sulfuric acid is introduced to lower the pH between 6 and 9 prior to starti ng discharge to the cooling pond.

Unit 4 and 5 combustion turbine offline washwater is sent to the low volume waste basin. (Process equi pment cleaning water).

 Sanford stated that the basins are lined. [NOTE TO SANFORD: Please provide the type and thickness of liner used.]

RESPONSE: High density polyethyl ene (HPDE) – 80 mils or 0.08 cm

 The cooling pond is not lined and has a vol ume of 3.1 billion gallons. Statistics on the design and inspection of the cool ing pond can be found in Attachment 1. Approximately 5,000 gpm evaporates, 10,000 gpm is used for the cooling water intake, and 5,000 gpm is blown dow n to the St. John’s River.Page 5Table 1. Site Visit AttendeesNameOrganization (Representing)TelephoneE-mailRandy Hopkins FP&L Sanford Plant 386-575-5385 Randy.Hopkins@FPL.comBrad WilliamsFP&L Sanford Plant386-575-5211David.Williams@FPL.comBruce StuartFP&L Sanford Plant386-575-5244Bruce.Stuart@fpl.comRon HixFlorida Power and Light561-691-7641 Ron.Hix@FPL.comChristian KiernanFlorida Power and Light561-691-2781 Christian.kiernan@FPL.comDonna HillUWAG205-257-5234 dbhill@southernco.comRon Jordan EPA/Office of Water 202-566-1003 jordan.ronald@epa.govDeb Bartram ERG (Contractor to EPA) 703-633-1669 deborah.bartram@erg.com[Note to Sanford: Please fill inmissing contact information.]RESPONSE: Please note that Gary Kowalczykwas the Sanford Plant General Manager during the initial site visit, but is now located at adifferent site. David “Brad” Williams is now the Sanford PlantGeneral Manager. Mr. Stuart’s information and correct spellingof name isalso included.