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 acre s and currently employs 70 people.

 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. Th e 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.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.

 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.

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 runPage 3

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 walls cons tructed with soil-cement. Each power

block wet surface 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 nominal level in the cool er basin and fluctuates based upon evaporation / drift rate. 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. A copy of this analysis is provided as Attachment 2.

Wastewater Treatment

 A water flow diagram of the plan t is included as Attachment 3.

 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.

 Unit 3 metal cleaning wastewater, includi ng turbine cleaning wash water, is transported to a lined basin, where sodium hydroxide is added to elevate the pH and precipitate out any metals. The wate r is retained for 24 hours. The basin includes two mixers. Once precipitation ha s 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 S.U. The wastewater is then discharged to the cooling pond discharge canal over a period of about 3 days.

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

 Sanford stated that the ba sins are lined with high density polyethylene (HPDE)

with a thickness of 80 mils or 0.08 cm.Page 4

 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 Plant386-575-5211 David.Williams@FPL.comBruce StuartFP&L Sanford Plant386-575-5244 Bruce.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.comNote: During the site visit Gary Kowalczykwas the Sanford Plant GeneralManager, but is now locatedat a different site. David “Brad”Williams is now the Sanford Plant General Manager.