Draft Notes from Site Visit at Florida Power 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 ab out the operations at the plant , specifically the waste streams associated with the oil

- fired units and the combined cycle units

. Table 1, located at the end of this memorandum , identifies the site visit participants. The presentation that the Sanford pers onnel gave during the site visit 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 xxx people. [QUESTION FOR SANFORD: How many people are employed by the plant?]

**•** Sanford began operations in 1925 when Units 1 and 2 began operating. Units 1
and 2 were both oil

- fired units and were retire d in 1964.

**•** Sanford currently operates three electric generating units at the power plant, with a gross generating capacity of 2,050 MW [NOTE TO SANFOR D : Please confirm total gross capacity.] . The table below contains some general information for the
thre e generating units.

Unit Installation Date Gross Capacity (MW) Fuel Type NOx
Control

3 1958 150 #6 Fuel Oil and/or
Natural Gas

4 1972 Repowered in 2003 362 (steam turbine) 600 (4 combustion turbines) Natural Gas

– Combined Cycle Low NOx
burner

5 1973 Repowered in 2002 362 (steam turbine) 600 (4 combustion turbines) Natural Gas

– Combined Cycle Low NOx
burner [QUESTION FOR SANFORD : Please provide any missing information. ]

Unit 3 Operations

**•** Unit 3 was placed in an extended shut down in October 2008. If Sanford chooses to bring Unit 3 back online, it would likely be within 30 days; however, the unit can be restarted as quick as 7 days, if needed.

**•** Unit 3 burns either #6 distillate fuel oil or natural gas, primarily depending on the current market pric e.

**•** The plant burned 2.5 million barrels of oil 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.Page 2

**•** When Unit 3 is operating, the ash is collected daily through t he e conomizer
h opper, a ir p reheater w ashes, and b oiler w ashes , and transferred to the ash treatment system once per day.

**•** Air preheater wash cycles are based on differential pressure. The washes typically occur approximately once every two weeks if the uni t 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 c ollection basin, then it is pumped to the ash basin (a lined basin).

**•** Approximately 1,000

- 1,500 gallons are generated during each economizer wash cycle.

**•** The boiler fireside washes occur during maintenance overhauls if the unit is exhibiting difficulty mai ntaining steam temperature. When unit 3 was in operation, the boiler fireside wash would occur once per year.

**•** FP&L staff indicated that conventional plants burning #6 fuel oil, such as FP&L’s Manatee, Martin, and Turkey Point plants, typically sluice the ash to an ash basin. For units where gas is primarily burned, any 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 Po int plants.]

**•** Unit 3 has once

- through cooling water supplied by the St. John’s River.

**•** Unit 3 is operated as a peaking unit, supplying electricity primarily in the summer
months.

Combined Cycle Unit Operations (Units 4 and 5)

**•** Units 4 and 5 originally w ere fueled by oil and natural gas. These units were repowered in 2002 and 2003 (i.e., converted into combined cycle units).

**•** Each unit has four combustion turbines and one steam turbine. During the site visit, both units were operating with 3 combustion tu rbines 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 water from a 1,100

- acre cooling pond built between 1970 and 1971. Water is recirculated from the pond to the units. Makeup water to the cooling pond comes from the St. John’s River. The pond is not lined, but has engineered embankment walls 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?]

**•** The efficiency of Units 4 and 5 decreases as the combustion turbine blades become dirty. Two types of water washes may be performed:Page 3

**•** 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 operating for approximately five minutes and evaporates. There is no discharge from this operati on.

**•** 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 frequently in summer) and generate about 2,000 gallons of wastewater, which is sent to the low volume wastewater basins. The plant has conducted a TCLP analysis of the wastewater. [NOTE TO SANFORD: Please provide a copy of the analysis.]

Wastewater Treatment

**•** A water flow diagram of the plant is included as Attachment 2.

**•** Low v olume 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, prior to discharge to the cooling pond discharge canal. The plant monitors t he discharge to the canal for TSS and oil and grease.

**•** Metal cleaning waste, including turbine cleaning wash water, is transported to a lined basin, where precipitation chemicals are added and the water is retained for
24 hours. The basin includes two mix ers. The 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. ]

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

**•** The cooling pond is not lined and has a volume of 3.1 billion gallons. Statistics on
the design and inspection of the cooling 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 down to the St. John’s River.Page 4

Table 1. Site Visit Attendees

Name Organi zation (Representing) Telephone E

- mail

Randy Hopkins FP&L Sanford Plant 386

- 575

- 5385 randy_hopkins@FPL.com

Gary Kowalczyk FP&L Sanford Plant 386

- 575

- 5211 Gary_kowalczyk@FPL.com

Bruce Stewart FP&L Sanford Plant

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

Donna Hill UWAG 205

- 257

- 5234 dbhill@southernco.com

Ron Jordan EPA/Office of Water 202

- 566

- 1003 jordan.ronald@epa.gov

Deb Bartram ERG (Contractor to EP A) 703

- 633

- 1669 deborah.bartram@erg.com

[Note to Sanford: Please fill in missing contact information.]