Text

Forwards NPDES Permit FL0000159,effective 881001,per Tech Specs App B,Part II, Environ Protection Plan & Related Info
	ML20154M113
Person / Time
Site:	Crystal River
Issue date:	09/14/1988
From:	Widell R; FLORIDA POWER CORP.
To:	; NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
	3F0988-08, 3F988-8, NUDOCS 8809270070
	Download: ML20154M113 (110)
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Florida Power COmPOMAfiOld September 14, 1988 3F0988-03 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Environmental Protection Plsn

Dear Sir:

Pursuant to the Crystal River Unit 3 Technical Specifications Appendix B, Part

11. "Environmental Protection Plan". Section 3.2 (3), please find attached the National Pollulant Discharge Elemination System (NPDES) Permit No. FL0000159 which shall become effective on October 1, 1988.

Also attache:I is one copy of each of the following:

1) NPDES Application Facts Sheets

2) NPDES Permit No. FL0000159 Findings and Determinations 3

Respo'ises to comments on NPDES Permit No. FL0000159 4 Salt Drift Impact Assessment 5 Notice of NPDES Permit Determination if you have any questions concerning this matter, please contact this office. Rolf C. Widell, Director Nuclear Operations Site Support REF:RCW:wla Attachments xc: Regional Administrator, Region 11 Senior Resident Inspector 0s09270070 8s0914 g{ FDR ADoCK 05000 2 lN Post omce som 219. costat Ri.er, Flonca 32629 e Te'ephone 69X 795 3S02 A FIOWt Progress Com;any

/**% )Oi m'i'kig 1 g/ 7 UNITED STATES ENVIRONMENTAL PROTECTION AGF, k D[. b REGION sV 34: COURTLAND STREET h 9, g ATL ANTA. 4EORGI A 30388 1f j ':: p 3 g,dp0*\\ NU C CERTIFIED MAIL C-Sh*h.. ? am u m RECdTPf RECUESTED r. m REF: 4WM-FP Mr. John A. Hancock Vice President, Fossil Operations Florida Power Corportion P. O. Bor 14042 St. Petersburg, FL 33733 I RE: Final Issuance of NPDES Permit flo. FL0000159 Florida Power Conpany

Dear Mr. Bancock:

Enclosed is the Fational Pollutant Discharge Elimination System (NPDES) permit for the above referenced facility. mis action constitutes the Environmental Protection Agency's final pemit decision in accordance with 40 CFR 124.15(a). Any person may contest this decisinn by submitting a timely request for a htaring to the Regiomi Administrator under 40 CFR 124.74 or 124.114. Also enclosed is one copy each of the following: Findings and Determinations, Fact Sheet - revised pages, Responses to Coments 1 Salt Drift Irpact Assessment, and Notice of NPDES Permit Determinations. %e p3rmit will be effective as specified in the permit, provided that no request for a 1.aring is granted by the Agency under 40 C.F.R. 124.75 or 124.114 In the event that such r reTaest is granted: o For discharge (s) previously authorized by an NPDES cormit, the force and effect of the contested provision (s) of this permit will be stayed, and any corp 3rable provision (s) of the previous NPDES pemit as well as all uncontested provision (s) of this permit shall be fully enforceable and effective until the administrative review process is cocpleted, as provided by 40 CFR J 24.16 and 124.60. o For dischstge(s) not previously authorized by an NPDES permit, the Agency's granting of a hearing (requested by you or any otner person) will result in no authorization to discharge. In other words, there will not be an NPDES P3rmit authorizing the discharge (s) and if such a discharge (s) occurs, the discharge (s) will constitute a violation of Section 301 of the Clean WTter Act, (33 U.S.C. 1311) for which there is civil and/or criminal liability. If you wish to request a hearing under 40 CPR 124.74 or 124.114 you must suttnit a request (an original and two copies) to the Regional Hearing Clerk within thirty (30) days fren the receipt of this letter. Se request will be timly if miled by certified mil within the thirty (30) day time peritd. For the regaest to be valid, it must confom to the req 2ireets of 40 a. ?. 124.74. A copy of the requirements of 40 CFR 124.74 is enclosed.

_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Information on procedures pertaining to the filing of a hearing request or other legal matters may be obtained by contacting Ms. Jacqueline F. Colson, Assistant Regional Counsel, at (404) 347-2335. Sincerely yours, $4 61 W ce R. Barrett, Director Water Management Division Enclosures (7): Hearing Request Requirements Final NPDES Permit Fact Sheet Pages with Revisions Findings and determinations Responses to Coments Salt Drift I@act Assessment Notice of NPDES Determinations cc: Florida DER (with enclosures) )

A'aba ma CE go" 4, of pse AMales Ronca North Carolina United States W FC"*'"# #'* * *" 345 Court:and Street. NE Georf3 South caroma AG'"CY Atlanta, GA,:n%5 Kentucky T806855** s, EPA Environmental News e n043 eu.2004 .i PERMIT ISSUED FOR CRYSTAL RIVER POWER PLAN IN CITRUS COUNTY, FLORIDA The U. S. Environ-montal Protection Agency (EPA) has issued a National Pollutant 3 Discharge Elimination System Permit to Florida Power Corpora-tion (FPC) for Units 1-3 at th'o Crystal River Powe r Plant in Citrus County, Florida. Issuance of the permit resolves a longstanding controversy on measures needed for the control of waste heat from the facility. The permit limits the temperature of the discharge to 96.5' Fahrenheit (as a three-hour average) and 97.0'F at any time. To meet these requirements, FPC proposes to construct helper (non-recirculating) cooling towers which will cool a 9.: portion of the plant offluent to meet permit limitations. iu Also required by the permit is a 15 percent reduction in s u. plant flow during the months of November through April, construction of a fish hatchery, and a program of monitoring c seagrass recovery and seagrass planting (if inadequate natural .4 recovery occurs). Based on its assessment of salt deposition impacts at the site, EPA has concluded that there will be no significant impacts from salt drift from the new cooling towers at the site. A permit, to be issued by the Florida Department of Environmental Regulation, will place limits on the discharge of particulates (salt drift) to the atmosphere. The permit is required prior to the start of tower construction. September 1, 1988 / CONTACT: Hagan Thompson of EPA, 404/347-3004 6 e 3 4 - A 't

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o '.i,,, t wrmmMIL::s yQt"E72ZE2C' DRY /PME* G T [ Evidentiary Hearirn (40 CFR 124.74) (a) Within 30 days following service of notice of the Regional A Ministrator's final permit decision under 124.15 any interested person may suMit a reqJest to the Regional A&inistrator under paragraph (b) of this section for an evidentiary hearing to 7 ....>..ra==Wr.or.czantast. that.M =9 u. If such a regoest is suMitted by a person ether than the permittee, the person aball missiltaneously . serve a copy.nf the. request on the pe.rmittee. (b)(1) .In A.n

with.124.76, such roguests what 1 Etate asch legal or factual question alleged to be at issue, and their relevance to the pemit decision, together with a designation of the specific factual areas to be adjudicated and the hearing t'.me

..est.imated to be necessary for adjudicar. ion...Infor::ation ..i supportim the re7 Jest er other written documents relied upon to support the reqJect shall be suhitted as reTJired by 124.73 unless they are already part of the mininistrative record reqJired by 124.18. .;....... Note:. f t 2his paragraph. allows.the.sulsnission of requests.for tvidettiary hearings even though both legal ar.d factual issues may be .,. raised, or only legal issues may be raised. In the latter case, .a i because no factual icsues were

raised, the Regional Administrator would be reqJired to deny the request.

However, on review of the denial the A&ninistrator is authorized by 124.91(a)(1) to review policy or legal cca.iclusions of the Regions! Adminstrator.

I.PA is reqJiring ar. appeal CO the Administrator even of purely legal issues involved in a pemit decision to ensure that the A ninistrator will have an opportunity to review any pemit before it will be final and subject to judicial reviev. ,2) Persons reqJestirn.an evidentiary hearing.on an ?@!:S perrit under ( this section ray also reqJest an evidentiary hearing on a ItCRA or UIC pemit, PSD permits ray never be cade part of an evidentiary hearing

.. under enWt.L. 21s request is.sddect to call the requirwents of

, " pa;rr.g.@ (b)(1) of this r.ectica and in addition will be granted only .Lf: (i) Processirn of the itCRA or UIC pemit at icsue was consolidated with the processing of the !EDES permit as ptovided in 124.4; (ii) .she standards for granting a '.esting on the !EES pemit are r.et; 2he resolution of the IIP' S permit issues is likely to rake (iii) A necessary or apptcpriate modification of the RCRA or DIC pemit; and

e If a PSD permit is involved, a pemittee who is eligible for ($v) ' an evidentiary hearing under subpart E on his or het NPDES requests that the formal hearing be conducted under pemit ~ the procedures of Sutpart. F and the Regional Administrator

. finds. that consolidation is unlikely to delay final pemit issuance beyond the PSD one-year statutory deadline.

(c) 3hese requests s. hall also.contain: The name, mailing,' address,' e d' telephone 'amaber afs the person a III ..' making such regasst; s A clear and concise factual statenent'of the nature and scope 12) of the interest of the reqJesters (3) ':he na.es and addresses of all persons whoa the reqJester represents; and A statenent by the reqJester that, upon motion of any party 4) granted by the Presiding Officer, or upen order of the Presidirrj Officer sua snonte without cost or expence to any other party, the requester shall make available to appear and testify, the following: ':ho requester (1) (ii) All persons represented by the requester and All officers, directors, erployees, consultants, and agents (iii) of the requester and the percons represented by the requester. cenditions, as .(5) Specific references to the contested permit well as stryyested revised or alternative pemit conditions (including permit denials) which, in the judgencat of the reqJester, veuld be reqJired to irplement the purposes and policies of the CIA. .In.the.cise of. cia 11enges to the application of' control er '. ! 6 ) treatment technologies'identifed in the statenont of basis or identification of the basis for the objection, . fact sheet,~ lternative* techr. ologies " or.eco-bination c' 'the

, -.and a

technologies which the 'regaester believes are rsecessary to meet the regairements of the !MA. Identification'of.the permit obligations that are contested (7) or are inseverable from contested conditions and should be stayed if the request is granted by reference to the particular contested conditions varranting the stay. Hoarirrj regaests also nay ask that a formal hearirg be held (8) under the proceduren set forth in S'dpart F. An aIplicant Tcy take such a request even if the proceeding does net constituta

initial licensing
as defined in 124.111.

a .3 If the Regional Ad.tinistrator grants an evidentiary hearing (d) request in whole or in part, the Regional Mministrator shall identify the pemit conditions which have been contestec by the requetster and for which the evidentiary hearing has been granted. Permit conditions which are not contested or for o' which the Regional Administrator, han denied the hearing request shall not be affected by, or considered at, the evidentiary hearing.

'Ibe Regional Administrator shall specify N=

.ew itians.in writing. In.accordance with M4.60 (c). 4.* .' ( e) - mm Regional' A&sinistrator.unst grant or roeny all requests . :for an evid** h ry hearing on a particular..pemit.. All reqJests that are granted for a particular permit shall be coebined in a single evidentiary hearing. If)..m. Regirrial Mministrator (upon notico to all persons who /* have altedf muMitted hearing regoests) may extend the time allowd for sulnitting bearing reqacsts under this section for good cause. l t _)

jamg Permit No. FL0000159 Major non-POIW lf gh gl UNITED STATES ENVIRONMENTAL PROTECTION AGENCY w/ nrGION IV 345 COURTLAND STREET ATL A NTA. 4EORGI A 34345 MnHORIZATION TO DISCHAEE UNDE.R THE NATICNAL POLIl#Ah? DISCHAME ELIMINATION SYSTDi In ecrnpliance with the provisions of the clean Water Act, as emended (33 U.S.C.1251 et. seq: the "Act"), Florida Power Corporation P.O. Box 14042 St. Petersburg, Florida 33733 is authorized to discharge fecrn a facility located at Crystal River Power Plant Units 1, 2, and 3 Citrus County, Florida to receiving waters nared j Gulf of Mexico frcn discharge points enumerated herein as serial numbers 001, 002, 003, 004, 005, 006, 007, 008, 009, 010A,108, 011, 012, 013, and 014 (or 14A and 14B) in accordance with effluent limitations, nonitoring requirements and other conditions set forth in Parts I, II, and III hereof. The pemit consists of this cover sheet, Part In 12 page(s), Part II: 15 page(s), Part III: 4 page(s), Part IV: 2 pags(s), and Attachnents: 2. This permit shall beccme effective on October 1,1988. This permit and the authorization to discharge shall expire at midnight, Septanber 30, 1993. %N, j SEP 1 1983 Ihte Signed Bivce R. Barrett, Director Water Managanent Division l

= w PAIT 1 Page I-1 4 EFFLUDR LIMITATIQ1S AND 1031*IORitG RDQUIRIMDTIS Ibrmit 16. FID000159 1. Ibring the pericri beginning on the effective date and lasting through inplementation of flow reduction, the perinittee is authorized to discharge frun outfall(s) serial nunber(s', 001, 002, and 005 (once through cooling water fran Units 1, 2, and 3, respectively) and 010A, 0108, and 011 (intake screen backwash to the plant intake or discharge canals) to the site discharge canal to the Gulf of Mexico. Such discharges shall be limited and monitored by the permittee as specified below: EFFIUDF OIARACTERISTIC DISO!AICE LIMITATIOJS POII*IORING RDQUIRDDirS Instantaneous mily Ibily Measurcnent Sauple Maximum Average Maxinun Frequency 'IYpe Flow (MCD) 1897.9 Ibport N/A Continuous IW p logs IOD Discharge Tenperature (*C(*F)] See Delcw Ibport Peport Continuous Recorders Unit Temperature Rise (*C(*F)] See Delow Peport See Below Continuous Recorders Total Pesidual Oxidants ("ITO, mg/1) y 0.05 tJ/A ft/A 2/ week y Multiple grabs Time of TIO Discharge (mirVday/ unit) y !J/A fi/A 120 2/ week 2f Multiple grabs "Ihe discharge terTarature at the bulkhead line shall not exceed 39.4(103) for a period of more than three consecutive hours or a maxinun of 41.1L(106). Daily maxinun tenperature rise across the condensers of Units 1, 2, and 3 shall not exceed 9.4(17.0), 9.4(17.0), and 9.7(17.5), respectively. Neither shall the tenperature rise across the condenser of Unit 3 exceed 9.7(17.5) for a period of more than three cormecutive hours nor an instantaneous maxirun of 11.7(21). Total residual oxidants shall not exceed 0.05 ng/l in the discharge frun any individual condenser (4 condensers per unit). Intake screen backwash may be discharged fran OSil 010A, 0108, and 011 without limitation or nonitoring require-cents after passage through debris baskets, except that there shall be no discharge of floating oil. Debris ru'oved by the intake bar racks and debris baskets shall be dispaced of by landfill. Sanples taken in cornpliance with the monitoring requirements specified above shall be taken at the following location (s): TIO at the outlet corresponding to an individual condenser (4 condensers per unit); flow fron carbined circulating water punps; and tenperature at the intake and outlet corresponding to an individual unit (inlet tonperature is the average of the tenperatures measured at the inlets to the four condensers and outlet tenperature is the average of *he torperatures measured at the outlets from the four condensers), and at the interrection of the site discharge canal and the original bulkhead line. l y Limitations and monitoring requirements for total residual oxidants (TIO) are not applicable for any calerdar day in which chlorine is not added. 2f In the c'. cot that the normal chlorine addition period is to exceed 120 minutes / day / unit, 'ITO shall be monitored by continuous recorder (s). !bte: See attached certification for mixing zone requironents for chlorine. l

1 PART I Page I-2 Permit No. FIA000159 4 A. EFFIDEPR LIMITATIOJS AND MONI*IORTNG RIEUIREMENIS 2. During the period beginning on the implementation of flow reduction and lasting throurjh imp 1 mentation of of the helper moling systs, the permittee is authorized to discharge from outtall(s) serial number (s) 001, 002, and 005 (once through cooling water frus Units 1, 2, and 3, respectively and 010A, 0108, and 011 (intake screen backwash to the plant intake or discharge canals) to the site discharge canal to the Gulf of Mexico. Such discharges shall be limited and monitored by the permittee as specifled below: EFFIDDE OIAPACIT:RISTIC DISOIANCE LIMITATIONS MONI*IORING RBOUIRFMENIS Instantaneous Ibily Ibily Nasurenent Sanple Maxinum Average Maximum Frequency _ "Iype Flow (MCD) _1/ Feport N/A Continuous Pump logs IOD Discharge Tenperature (*C(*F)] See Iblow Pcport Report Continuous Hecorders POD Tmperature Rise (*C(*F)] N/A Report Heport Continuous Recorders Total Residual Oxidants (TFO, mg/1) 2/. 0.05 N/A N/A 2/ week 3/ Multiple grabs Time of THO Discharge (min / day / unit) 2f N/A N/A 120 2/ week 3/ . Multiple grabs 'Ihe discharge taperature at the bulkhead line shall not exceed 39.4(103) for a period of more than three consemtive hours or a maxinun of 41.1(106). Total residual oxidants shall not exceed 0.05 mg/l in the discharge from any indivicksal condenser (4 condensers per unit). Intake screen backwssh may be discharged from OSN 010A, 010B, and 011 without limitation or nonitoring require-ments after passage through debris baskets, except that there shall be no discharge of floating oil. Debris removed by the intake bar racks and debris baskets shall be dispaced of by landfill. Samples taken in conpliance with the monitoring requirments specified above shall be taken at the following location (s): TIO at the outlet corresponding to an individual condenser (4 condensers per unit); flow from combined circulating water punps; intake taperature at individual unit intakes (or water boxes); and discharge tmperature at the intersection of the site discharge canal and the original bulkhead line. 1/ Cmbined condenser flow frm Units 1, 2, and 3 shall not exceed 1897.9 MGD during the period of May 1st through October 31st of each year nor 1613.2 MGD during the romainder of the year. 2/ Limitations and monitoring requirments for total residual oxidants (THO) are not applicable for any calendar day in which chlorine is not added. 3] In the event that the normal chlorine addition period is to exceed 120 minutes / day / unit, THO shall be monitored by continuous recorder (s). Note: See attached certification for mixing zone requirements for chlorine. m- -_.,7

PAIE I A. EFFLUDTr LIMITATIOS AND MONITORItC REEUIREEDTIS Page I-3 Ibmit No. FIA000lS9 3. During the period beginning on imp 1 mentation of the helper ecolirg systs and lasting through expiration, the permittee is authorized to discharge from outfall(s) serial number (s) 001, 002, and 005 (once through cooling water from Units 1, 2, and 3, respectively); and 010A, 0108, and 011 (intake screen backwash to the plant intake canal) to the site discharge canal to the Gulf of Mexico. Such discharges shall be limited and monitored by the pemittee as rpecified below: EFFIEDIT OIARACIERISTIC DISCIIARGE LIMITATIOS MONFIORItC RDQUIPINDTIS Instantaneous Ibily Ibily Nasuronent Sanple Maximtzn Average Maximtsn _ Frequency 'Iype Flow (PCD) If Report IJ/A Continuous Ptmp logs IOD Discharge Terperature (*C(*F)] See Delow Peport Peport Continuous Ibcorders IOD Tmperature Rise (*C(*F)] See Below Peport Report Continuous Recorders Total Residual Oxidants (TIO, mg/1) 2/ 0.0S t1/A N/A 2/ week 2/ Multiple grabs Time of TIO Discharge (min / day / unit) 2/ N/A N/A 60 2/ 2/ week 2/ &ltiple grabs 'De discharge tecperature at the bulkhead line shall not exceed 35.8(96.5) as a tnree-hour rolling average nor 36.l(97.0) at any tine. Total residual oxidants shall not exceed 0.05 ng/l in the discharge fran any individual condenser (4 condensers per unit). Intake screen backwash may be discharged frcan OSN 010A, 0108, and 011 wi;:'mut limitation or monitorirg require-m.nts af ter passage through debris baskets, except thac there shall be no discharge of floating oil. Debris renovea by the intake bar racks and debris beskets shall be disposed of by landfill. Sampics taken in ccepliance with the conitorirn requironents specified above shall be taken at the following location (s): Flow fran the conbined circulating water ptznps, FOD discharge torperature at the intersection of the site discharge canal and the original bulkhead line, intake tenperature at individual unit intakes (or water boxes), and TIO at the outlet corresponding to an individual condenser (4 condensers per unit). 1/ Canbined condenser flow fran Units 1, 2, and 3 shall not exceed 1897.9 MGD during the period of May 1st through October 31st of each year nor 1613.2 FCD during the remainder of the year. 2/ Discharge of TIO fran the condenser (s) of each unit shall not exwed a maximtsa of 60 minutes each in any calendar day. During the period (s) when "ITO may be discharged frcsn OSN 001, 002, 005, 012, and 013, TIO may be discharged fran one or more individual condensers and/or *DO may be discharged fran either or both tower outfalls, individually or in any <xxnbination, provided that no individual point of discharge shall exceed a nuximtra instantaneous concentration of 0.05 mg/1. Limitations and monitoring requirements for TIO and tire of "DO discharge for OSN 001, 002 and/or 005 are not applicable for any calendar day in which chlorine is not added to OGN 001, 002, or 005, respectively. In the event tlut the normal chlorination addition period is to exceed 60 minutes / day / unit, TIO shall be monitored by continuous recorder (s). Note: See attached certification for mixing zone requironents for chlorine. I

FART I Page 1-4 Pemit No. FID000159 A. EFFil1ENT LIMITATICNS AND MONTIORIfC Rf00IREMENIS 4. Ibring the period beginning on the effective date and lasting through expiration the penaittee is authorized to discharge fran outfall(s) serial ntaber(s) 003 _1/ - Laundry and Shower Sump Tark (I.SST) [ includes laboratory drains] to OSN 006. I Such discharges shall be limited and nonitored by the pemittee as specified below: EFFIIJEFFT CllARACIERISTIC DISCIIARGE LIMITATIOtB MONI10 RING REQUIRENNIS Measurement Sample Ibily Average Daily Maxinnsa Frequency 'Iype Flow (MGD) Ibport leport 1/ batch Calculation i Oil and Grease (mg/1) 15.0 20.0 1/ batch Grab Total Susperx5ed Solids (ng/1) 30.0 100.0 1/ batch Grab Batches Ibport 2/ Ibport 1/ batch Iajs menever metal cleaning wastes are discharged through this serial rusnber, effluent shall not contain more than 8.345 Ito of total copper or total iron per million gallons of metal cleaning waste generated and shall be j monitored 1/ batch by composite sag le. NOTE: h radioactive ccmponent of this discharge is regulated by the U.S. Nuclear Regulatory Ocmunission under the Atomic Energy Act and root by the U.S.E.P.A. under the Clean Wter Act. hre shall be no discharge of floating solids or visible foam in other than trace amounts. Samples taken in compliance with the monitoring requirements specified above shall be taken at the following locations): discharge frca the LSST treatraent system prior to mixirg with any other waste strean. If Serial rasnber assigned for identification and monitoring purposes. 2f Report total batcles per :nonth. ]

A. EFFLUDir LIMITATIONS AND PONITORING RDQUIREM2iIS PART I Page I-5 5. During the period begint'ing on the effective date and lasting through expiration the Pt!rmit No. FID000159 permittee is authorized to discharge from outfall(s) scial ntsnber(s) 004 arul 009 - Ash pond discharges (Units 1 and 2 conbined) to the site discharge canal to the Gulf of Mexico. Such discharges shall be limited and nonitored try the permittee as specified below: EFFII'DTT CHARACIERISTIC DISCHANGE LIMITATICNS MONIl0RIPII REQUIRDtENIS (mrl/l except as noted) Measurunent Sample Ibily Average Daily Maximtsa Frequency 'IMw J Flow (MGD) Ibport Pcport 1/1My Instantaneous Oil and Grease 15.0 20.0 1/ Week Grab Total Suspended Solids 30.0 100.0 3/ Week Grab Grab y/, 3/ Heavy Metals f(/A Report 1/ Month Arsenic N/A 0.05 1/ Month Grab 2 Cadmitsn N/A 0.005 1/ Month Grab 2/ _ Chrunitsn N/A 0.050 IAtonth Grab 2/ %wr N/A 0.015 1/ Month Grab 2/ l l 1 N/A 0.3 1/ Month Grab 2/, y x1 N/A 0.05 1/ Month -ercury N/A 0.0001 1/ Month,. Grab Grab tiickel f(/A 0.1 1/ Month Grab g, / 0.025 1/ Month Grab 2f, Selenitsu N/A Zinc N/A 1.0 1/ Month Grab g The pH shall not be less than 6.5 standard units nor greater than 8.5 y standard units and shall be monitored 1/ day 2/. fore: Limitations and monitoring requirements are not applicable during periods of no discharge. Requirenents are applicable to each pond individually; however, during any month in dich ash pond use is discontinued for cleaning, analysis results for 'Iss and Os,G from both ponds may be averaged. There shall be no discharge of floating solids or visible foam in other than trace maounts. Seples taken in ccupliance with the monitoring requirements specified above shall be taken at the following location (s): discharge frcza each ash pond effluent prior to mixing with any other weste stream, except for paraneters to be monitored at the edge of the mixing zone. 1/ Monitoring for heavy metals shall include total arsenic, iron, and selenitsu. 7/ Corxlition of State pennit(s). 3/ Monitoring shall be at the edge of the mixing zone which is that portion of the site discharge canal that extends 100 feet cast of OSN 004 and 400 feet west of OGN 009. tbte: See attached certification for mixing zone requirements for oil and grease.

PART I A. EFFLUENT LIMITATIONS AND MONI~IORING RDOUIRD1ENIS Page I-6 ) i Permit No. R0000159 6. During the period beginning on the effective date and lasting through expiration the i pennittee is authorized to discharge frczn outfall(s) serial ntaber(s) 006 - Nuclear Services and Decay Heat Seawater Syston discharge to the site discharge canal to the Gulf of Mexico (includes OGN 003, 007, the Evapor-ator Condensate Storage Tank (ECST) discharge and the Condensate Systen (CD) discharge). Such discharges shall be limited and monitored by the permittee as specified below: 1 l EFFI1JFNr OIARPfIERISTIC DISCHARGE LIMITATIONS MONI~IORING REQUIRINNTS l Daily Daily Instantaneous masurement Sample Average Maximtse Maxism.sn Frequency Type Fi m (MCD) Total Residual Oxidants (TRO, ng/1). & port Report N/A Contirwum Ptap logs Time of *ITD Discharge (mirVday/ unit)J/ l N/A N/A 0.05 1/ week Multiple grabs Jf N/A Report N/A l/ week k ltiple grabs ECST Flcw (MGD) kport Report N/A 1/ Day Iojs CD Syston Flow (MGD) Report Report N/A 1/ Day Iogs Total Suspended Solids (mg/1) 30.0 100.0 N/A 1/ Week Grab { Oil and Grease (mg/l) 15.0 20.0 N/A 1/ Week Grab i i menever metal cleaning wastes are discharge through this serial number, effluent shall not contain more than 8.345 lbs. of total copper or total iron per million gallons of metal cleaning waste generated and shall be q r.onitored 1/ batch by ccmposite sanple. 4 Separate chlorination of this discharge is not authorized; however, discharge of TFO due to chlorination of j 05N 005 is permitted. 1 rKyrE: 'Ihe radioactivc conponent of this discharge is regulated by the U.S. Nuclear Regulatory Consnision under the Atcunic Energy Act and not by the U'.S.E.P.A. under the Clean Water Act. 'Ihe pit of the conbined discharge (006) shall not be less than 6.5 standard units nor greater than 8.5 standard units and shall te monitored 1/ day during periods of 007 and/or CD discharge. If no discharge frcza 007 or CD occurs, sampling shall be at a convenient time. "Ihere shall be no discharge of floating solids or visible foma in other than trace amounts. 4 Samples taken in compliance with these monitoring requirements specified above shall be taken at the following location (s): TRO and pH at the point of discharge prior to entering the site discharge canal (006); flow at the conbirxx1 inth water ptmps; and flow, ircn, copper, "IES, and 0&G at the ECST and CD discharges to OSN 006. 1/ Limitations and monitoring requirements for total residual oxidants (TNO) are not applicable for any calendar day in which chlorine is not added to OSN 005. Note: See attached certification for mixing zone requirements for chlorine. ,,7-_y- .-.,m--._-. _r,

PART I Page I-7 Permit No. I E 000159 A. EFFIDE2fr LIMITATICNS AND M[NTIORING RDOUIRNa 7. During the period beginning on the effective date and lasting through expiration the permittee is authorized to discharge fron outfall(s) serial turber(s) 0071/ - Regancration Waste Neutralizaticn Tank (Spr-1) to 06N 006. Such discharges shall be limital and monitored by the perrittee as specified below: EFFIEDTT OIARACTERISTIC DISOIARCE LIMITATIONS MONTIORING REWIRDetrS Measurement Sanple Ibily Average Daily Maxistan Frequency 1ype Flow (MCD) Ibport Report l/ batch Calculation Oil and Grease (mg/1) 15.0 20.0 1/ batch Crab Total Suspended Solids (mg/1) 30.0 100.0 1/ catch Grab Batches Ibport 2/ Report 1/ batch Iajs khenever metal cleaning wastes are discharged through this serial nteber, effluent shall not contain more than 8.345 lbs of total copper or total iron per million gallons of netal cleaning waste generated and shall be monitored 1/ batch by cmposite sanple. rKyrE: The radioactive component of this discharge is regulated by the U.S. Nuclear Regulator Caunission under f the Atczalc Energy Act and not by the U.S.E.P.A. under the Clean Water Act. There shall be no discharge of floating solids or visible foan in other than trace amounts. Sampics taken in compliance with the monitering requirements specified above shall be taken at the following location (s): discharge from the SUr-1 treatment system prior to mixing with any other waste stream. I Serial runber assigned for identification and monitoring puqxxscs. Report total batches per month. i

PART I Page I-8 Permit No. FID000159 A. EFF1JJf7tr LIMITATIONS AND MONITORItG RBOUIRDefrS 8. During the period beginning on the effective date and lastir.; through expiration the permittee is authorized to discharge from outfall(s) serial rumver(s) 008 - Coal pile runoff (Units 1 and 2) to snarshy area. Such discharges shall be limited and monitored by the per.aittee as specified below: EFFWDir OiARACITRISTIC DISOIARCE LIMITATIO S MONIl0 RING REQUIREMDFTS Measuronent Sample Instantaneous Maximus Frerpency 1ype Fl w (MGD) Heport lAdeck Grab Total Suspended Solids (ag/1) 50_lf 1Adeck Grab %e pH shall not be less than 6.5 standard units nor greater than 8.5 standard units and shall be monitored 1/ week on a grab sample If. NOTE: Limitations and monitoring requirenents are riot applicable during periods of no discharge. %ere shall be no discharge of floating solids or visible foasa in other than trace anotets. q Sanples taken in coupliance with the monitoring regoirements specified above shall be tSen at the following location (s): points (s) of discharge frcan treatment system prior to mixing with any cther taste stream. If Applicable to any flow up to the flow resulting frose a 24-hour rainfall event with a Wie rearrer.ce l interval of once in ten years. %e treatment systesa shall be capable of containing a 10-year, 24-hour rainfall event. 3 i 1 l l e i e 4 4 i* --- - - -, - = - -

PART I Page I-9 Permit No. Fth000159 A. EFFWDir LIMITATIONS AND MONTIORIFC RIIXIIRIMENTS 9. During the period beginning on implmentation of the helper cooling system and lasting thm.gh expiration, the permittee is authorized to discharge from outfall(s) serial nunber(s) 012 and 013 (helper cooling tower effluents) and 014 (or 014A and 014B - intake screen backwash) to the site discharge canal to the Gulf of Mexico. Such discharges shall be limited and monitored by the permittee as specified below: MONI10RIPC RE00IREMENIS EFFwDir CIARACIIRISTIC DISOIAICE LIMITATIQ4S -Measurment Sample Instantaneous Daily Daily Maximise _ Average Maximaan Frequency _1ype Flow (FCD) IR Heport Report Continuous Pimp lays Total Reaidual Oxidants (1FO, ng/1) If 0.05 2/ N/A N/A Continuous Recorders Time of TIO Discharge 2/ N/A N/A 60_1/ Continuous Recorders Cooling towers shall be cperated as weessary to assure that the discharge temperature at the bulkhead line does not exceed 35.8(96.5) as a three-hwr rolling average nor 36.1(97.0) at any time (see Page I-3). Intake screen backwash may be discharged frcan OSN 014 (or 014A and 014B) without limitation or annitoring requirments after passage through debris baskets, except that there shall be no disdarge of floating oil. Debris rmoved by the intake bar racks and debris baskets shall be disposed of by landfill. Seples taken in ecupliance with the monitoring requirments speciGed above shall be taken at the folicwing location (s): Ficw from the tower intake punps and "IFO at each cooling tower outfall (to the site discharge canal). 1/ Discharge of THO from ead cooling tower outfall shall not exceed a maximum of 60 mirutes each in any calendar day. During the period (s) when 1F0 may be discharged frce OSN 001, 002, ')05, 012, and 013,1FO rey be discharged frcza one or nore individual ccexkensers and/or "mD may be discharged frcun either or both towar outfall(s), individually or in any ccabination, provided that no individual point of discharge shall 2 Limitations and monitoring requirements for / exceed a ma 6 s instantaneous concentration of 0.05 mg/l TIO and time :t THQ discharge for OSN 012 and/or 013 are not applicable for any calendar day in which chlorine is not added to the tower systens discharging through OSN 012 or 013, respectively. 2/ Limitation shall be 0.01 mg/1, unless a mixing zoie(s) (MZ) is granted by ITER. If a MZ is granted, the ] limitation will be 0.05 mg/l at OSN 012 and 013 and 0.01 mg/l at the edge of the MZ. O

FART t ~ Page -10 Pe mit No. 410000159 A. EFTWDC f. IMITATIONS AND MJNITORING REQUIRMENTS

10. During the period beginning on the effect.ive date and lasting through expira-tion the pemittee is authorized to discharge stom water frm diked petroleum storage or handling areas, provided the following conditions are net Such dicharges shall be limited and monito:wd by the pemittee as specified i

below: i a. The facility shall base a valid SPCC Plan pursuant to 40 CFR 112. t b. In draining the diked area, a portable oil skimer or similar device or i absorbant nacerial shall be used to renove oil and grease (as indicated by the presence of a sheen) imediately prior to draining. l Monitoring records shall be maintained in the form of a log and shall 4 c. contain the following infomation, as a mininums (1) Date and time of discharge, i 1 (2) Estinated volu-e of discharge, l t j (3) Initials of person making visual inspection and authorizing discha:ge, and 7 l (4) Observed conditions of stom water discharged. 5 I d. There shall be no discharge of floating solids or visible foam in other than *, race a:tounts and no discharge of a visible oil sheen at any time. j i l' E 4 i J l i i l i l i 1 1 1 I 4 l =t"'wW,w shv ^V9F%+ 4 "w

.b PART I P:rt I-11 Permit Mo. FL0000159 l t B. SCHEDULE OF CCNPLIANCE

1. The permittee shall achieve cogliance with the effluent limitations specified for discharges in accordance with the following schedules f

a. Effluent Ficw Peduction (001 and 002) r

1. Progress report 02/28/89

2. Progress report 08/31/89

3. Progress report 02/28/90 08/31/90

4. Inta11ation empleted -

b. Hatchery (Part III.K) 02/28/89

1. Submit necessary pemit applications

==

2. Start construction 08/31/89 L1/30/89

3. Initial plan and budget -

4. Progress report --

12/31/89 l

5. Impiment operation -

= - - - 03/31/90 t 11/30/XX l

6. Subsequent annual plan and budget 1

03/31/91

6. First annual repoct -

= = - - - -

7. Subsequent Mnual Reports ---

03/31/XX l

c. Helper Cooling Towers (001, 002, and 005 and Part I'I.L)

1. Submit ecqlete PSD application

0 5/31/8 9

2. Start construction and progress report -

0 2/28/90

3. Progre s s report - -

= -------- = - ---------

08/31/90
02/28/91

- - - - - - - - - ~ ~ - - - -

4. Prcgress report ----

08/31/91

5. I g lement operation -

-=- =--- - -- 4 i

d. Condenser Cooling Water Ficw Verification (Par *. III.M) l l

1. Pe po rt --------- --- ----------------------

02/28/92 i

e. Discharge Te porature Mnitoring (Part III.N)

(

1. Start f ield surveys --------------------------- ~-- **08/31/91

02/28/92

2. Submit report --------------------- d) - ---

05/31/9 2 l

3. Iglement changas, existing eqpt. (if require l

4. I g lement changes, new eqpt. iif required) --------

02/28/93 f

f. Seagrass Mnitoring and Planting (Part III.0) 4 l

1. Biological survey -------------------------- Fall 19 91 1

2. Biolog ical survey ------------------------------ Fall 19 9 3 4

3. S ubmi t re po r t ------------------------ ------------- 11/30/93 I c l ITDtS 4 - 23 ARE APPLICABLE CtiLY IF NEEDED, BASED Ct1 PESUL'DS OF 'IEE ABOVE REPORT WID MAY EE TdNINATED_ Ctl PEFMITTItG AUIHORITY APPFCVAL IFAHE'1 SUBSEQUEffr DATA INDICATES THAT !D FLTCHER ACTICt1 IS RD. IFED. ~~ N s 04/01/94 J 4. Sprig plant ing --------~~----------------- Fall 19 9 5

5. Biolcg ical survey ------------------------ -----~~

l

6. Sulmit annua l repor*. --------------

11/30/95 l

1

Date is subject to slippage if the the PSD Permit iW not issued by the FDET by l

and to advancement if the PSD Perr.it is issued sooner; i.e., start of 01/31/90 construction is to be not later than one month af ter issuance of the PSD pemit, and other ccrpliance dates similarly slipped or advanced. j i l 1 4 I

PMC I Part I-13 Pemie No. FL0000159 l B. SCHEDJIE OF COMPLIANCE (continued)

1. f. & @ rass Monitoring and Planting (continued)

--- Fall 199 6

7. Biological Survey -

4

8. Submit final report -

= 11/30/96 1

9. Start plot planting 04/01/97

10. Biological survey Fall 1997

11. Sutxhit report 11/30/97 04/01/98

12. Start plot planting Fall 1998

13. Biological survey

14. Submit report 11/30/98

15. Start plot planting 04/01/99

16. Biological survey ---

Tall 1999 11/30/99

17. Submit report -

04/01/00

18. Start plot planting

-- Fall 2000 l

19. Biological survey -

= 11/30/00

20. Submit report -

- = -

04/30/01 j

21. Start plot planting

-- Fall 2001 1

22. Biological survey -----------------

- 12/31/01 i

23. Submit ceport ----------

i

g. BMP Plan (Part IV)

- 03/31/89

1. Develop plan -------

03/31/9 0

2. Implemen: plan --

-= 2.16 later than 14 calendar days follcwirsg a date identif red in the above schedule of ccrnpliance, the permittee shall suteit either a report of progress, or, in the case of specified actions being required by identified dates, a written notice of ecq 11ance or nonecq11ance, any re.edial actions taken, and probability of meting the next scheduled requ;rement. s l 4 i j l ) l 1 1 i I J 1 I l e A

j Part II Page II-1 PART II STANDARD CDNDITIOt:5 FOn NPDES PERMITS SECTION A'.. GDTIPE CDNDITIONS 1. Duty to o' xv1v a 'Ihe permittee .i.gs-yliance.must ecurply with all conditions of this permit. for enforcement actions for permit temination, revocatio Any permit modification; or for denial of a permit renewal application.

2. ' Penalties for Violations of Permit Conditions Any' person who violates a permit condition is subject to a civil penalty n e

to exceed $10,000 per day of such violation. $2,500 nor more than $25,000 per day of violation ' more than 1 year, or both. 3. Duty to Miticate 2 h permittee shall take all reasonable steps to minimize or prevent discharge in violation of this permit which has a reasenable likelihood of 4 any adversely affecting human health or the envirorrnent. 4. Permit POdification After notice and opportunity for 'a hearing, 1 this permit may be modified, terminated or revoked for cause (as described in 4C CFR 122.d2 et seq) including, but not limited to, the following: i ~ Violation of any terms or conditions of this permits a. i b. Obtaining this permit < fully all relevant facts;by misrepresentation or failure to disclose changw, in any conditions that requires either te@orary c.,' A interruptic1 or elimination of the permitted discharges or t,, 'd. ' Informatier. newly seguired by the Agency indicating the disc l poses a threat to human health or welfare. i l s

o l Part 2I l Page.II-2 i If the pemittee belines that any past or planned activity would ise cause for f modification or revocation and reissuance under 40 QR 122.62, the pemittee must report such information to the Permit Issuing Authority. The sul.rtittal of a new application may be required of the permittee. The filing of a i request by the pemittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncogliance, does not stay any permit condition. j ) 5. 1W ic Pollutants 3 Notwithstanding ' Paragraph A-4,

above, if a toxic effluent standard or l

prohibition (ihcluding any schedule of cogliance specified in such offluent j etandard or prohibition) is established under section 307(a) of the Act for a toxic pollutant which is present in the discharge and such standard or j prohibition is more stringent than any limitation for such pollutant in this l l permit, this permit shall be sodified or revoked and reissued to conform to the toxic effluent standard or prohibition and the pemittee so notified. 1 J j the permittee shall cogly with effluent standards or prohibitions established j under section 307(a) of the clean Water Act for toxic pollutants within the [ ] time. provided in the regulations that establish those standards or [ prohibitions, even if the permit hac not yet been modified to incorporate the { requirement. j

6. ' C' vil and Criminal Liability i

Except as provided in permit conditions on ' Bypassing' Section B, Para' graph l B-3, nothing in this permit shall be construed to relieve the permittee f em civil or criminal penalties for noncogliance. 7. oil and Hazardous substance Liability Mothing in this pemit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under section 311 of the Act. i 8. state laws i Nothing in this permit shall be construed to preclude the institution bf aity j i legal action or relieve the permittee f rm any responsibilities, liabilities, l or penalties established pursuant to any applicable State law or regulation ' 'l under authority preserved by section 510 of the Act. l 4 l 9.',Pr$perty Rights, f Ne'iNuance of this permit does not convey any property rights of any scrt, I or,any exclusive privileges, nor does it authori:e any injury to private j i property or any invasion of personal rights, not any inf ringement of Federal, [ State or local laws or regulations. j i j ,t

Part 88 Page II-3

10. Cushere or offshore construction 21s permit does not authorize or approve the construction of any onshore or offshore physical structures or facilities or the undertaking of arry work in any waters of the United states.

11. Severability ne provisions of this permit are severable, and if arr/ provision of this

permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

12. Duty to Provide Information ne pemittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the Pemit Issuing Authority may request to determine whether cause exists for modif ying, reveking and reissuing, or terminating this permit or to determine ccepliance with this permit.

Se permittee shall also furnish to the Permit Issuing Authority upon request, copics of records required to be kept by this permit. SECTIOtt B. OPERATION MD MADrrDW1CE OF POLUTIION CDimt0LS 1. Proper Operation and Maintenance ne permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve conpliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. nis provision requires the operation of back-se or auxiliary f acilities or similar systems which are installed by a permittee only when the operation is necessary to achieve ccryliance with the conditions of the permit. 2. Need to Malt or Reduce not a Defense It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain ccepliance with the condition of this permit. 3. Bypass of Treatment Facilities a. Definitions (1) ' Bypass' means the intenticnal diversion of vaste strea.s f t:n any portier, of a treatment facility, which is not a designed or established cperating rede for the facility. i

Part II Page 11-4 (2) ' severe property damage' means substantial physical damage to 1 property, damage to the treatment facilities whien causes them to becme inoperable, or substantial and permanent loss of, naturs1 resources which can reasonably be expected to occur in the absence of a bypass. Severe property damego does not mean economic loss caused by delays in production. b. sypass not exceeding limitations. l Se permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. mese bypasses are n't subject to the provisions of Paragraphs c. and d. of this o section. c. Notice (1) Anticipated bypass. If the permittee knows in advance of the need for a bypass, it shall suknit prior notice, if possible at least ten days before the date of the bypass including an evaluation of the anticipated quality and effect of the bypass. (2) Unanticipated bypass. Se permittee shall sulnit notice of an unanticipated bypass am required in Section D, Paragraph D-8 4 (24-hour notice). 6. Prohibition of bypass. (1) typass is prohibited and the Permit Issuing Authority may take j enforcement action against a permittee for bypass, unless: (a) pypass was unavoidable to prevent loss of life, personal injury, or severe property damages I ) (b) There were no feasible alternatives to the ty u, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal pericxts of equipment downtime. 21s condition is not satisfied if adequate back g equipment should have been installed in the esercise of reasonable engineering judpent to prevent a bypass which ocaarred during normal periods of eqai; rent dcuntime or preventive maintenance and 1 (c) Se permittee sutnitted notices as required under Paragraph

c. of this section.

i 1 (2) The Permit Issuing Authority may approve an anticipated bwass, l after considering its adverse effects, if the Pomit Issuing Authority detemines that it will meet the three conditions listed above in Paragraph d.(1) of this section. y .,. _. _. - _ _ _ _ _ _ -, _ =. _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _. _.. _ _ _ _ _ _ _ _ _

P3W 33 Page 88-5 4. Upsets ' Upset' means an exceptional incident in which there is unintentional and li.eltatiens te@crary renexpliance with techno1cT/ based permit effluent because of f actors beyond the reasonable control of the permittee. An upset does net include nonexpliance to the extent caustd by cperatiensi

error, irpecperly designed treat:nent facilities, inadequate treat.ent facilities, lack of preventive maintenance, or careless or irpreper c9e rati'en.

An upset constitutes an affimative defense to an action brought for ncn-capliance with such technology based pemit li. itation if the requirements of 40 crR 122.41(n)(3) are met. 5. Removed substances j ':his per: nit does net authorize discharge of solids, sludge, filter backvash, i I or other pollutants renoved in the course of treatment, ce centrol of f wastevaters to waters of the United States unless specifically li:ited in part 1. SECTT0t! C. Ktt!':tRING AND R1'CCPOS 1. Representative Samling Sarples and measurements taken as required herein shall ce representative of the volume and nature of the senitored discharge. All sarples shall be taken at the senitoring points specified in_this pemit and, unless other >ise specified, before the effluent joins o a diluted by any other wastestrean, body of water, or substance. Monitoring points shall not be changed without notification to ard the approval of the Permit Issuirq Authority. 2. Flew Heasuremnts. flew measurement devices and methods consistent with accepted Apprcpriate scientific practices shall be selected and used to insure the accuracy and reliability of measurements of the volume of monitored discharges. 'ste devices shall be installed, calibrated and maintained to iraure that the accuracy of the measurements are consistent with the secepted capability of that type of desico. Devices selected shall be capable of measuring flevs with a maxina deviatim of less than i 10% irom the true discharge ratas throughout the range of egocted discharge volumes. Once-through condenser cooling water flow which is senitored by logs, or purp hour meters as v specified in Part I of this permit and ba on the manuf acturer's purp curves not be subject to this requirenent. Guidance in selection, shall installatim, calibration and eteratien of acceptable flow measure.ent devices can be obtained f rom the folicwirn references: 1. 'A Guide of Methed; and Standards for the Measurerent of Water Flev', U.S. Departant of Cemerce, !!atienal Bureau of Standards, !35 Special Publication 421, May 1975, 97 pp. ( Available f ren the U.S. G3ve rr. ent Printing Cffice, Washingten, D.C. 20402. Crder by SD catalcq tb. C13.10:4 1.) 2. ' Water Meas 1rerent Manual', U.S. Depart.9ent *:f Interior, Bureau cf pe-l a-atien, Secend

Editien, Revised

Rwrint, 1974, 327 pp.

(Available frcn the U.S. Goverr. ment Printing Cffice, Wtshingten, D.C. 20402. Order by catalog !;o. 127.19/2:W29/2, Stock 14. S/N 24003-0027.)

I Part II Page II-4 (3) ' Flow Measurement in O Department of Comerce, pen Channels and closed Cbnduits', U.S. National Bureau of standards, its special Publication 484, October 1377, 962 pp. (Available in paper copy or microfiche from National TWhnical Information Service (h":IS ), Springfield, VA 22151. Order by NTIS Ho. P5-273 535/5sT.) (4) 'MPDES Cagliance Flow Heasurement Manual *, U.S. Environmental Protection Agency, office of Water 8hicreement, blication MCD-77, septester

Ital, 135 p.

(Available frers the General services l Adninistration (taRC), Centralized Mailing Lists services, Building 41, Denver Federal Center, Denver, CD 80225.) 3. Monitorim Proe*Nres_ Monitoring mst be conducted accordim to test procedures aggroved urder 40 CFR Part 136, unless other test procedures have been specified in this permit. 4. Penalties for Taniperim i the Clean water Act provides that any person who falsifies, tanpers with, or knowingly renders inaccurate, any monitoring device or method required to be maintained under this permit shall, won conviction, be punished by a fine of not nere than $10,000 per violation, or by inrisoment for not more than 6 months per violation, or by both. l 1 5. Retention of Records The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrunentation, egies of all reports required by this permit, and records of all data used to caplete the applicatice for this permit, for a period of ac least 3 years fren the date of l the sample, sensurement, I report or application. This period may he extended by the Permit Issuing Authority at any time. 6. Reeerd Cbntants I Records of monitoring infermation shall include i 4 i i The date, esact place, and time of sargling or mouurements a. i b. The individual (s) who performed the sarpling or measurarnents; c. The date(s) analyses were perforaed; d. 2e individual (s) to performed, the analyses; j e. 2e analytical techniques or methods used; and i f. The results of such analyses. i J

Part II Page II-7 7. Inspection and Entry me permittee shall allcw the Pemit Issuing Authonty, or an authorized representative, upon the presentation of credentials atd other docuner.rs as may be required by law, to: Enfer' upon the permittee's prersises where a regulated facility or a. activity is located or cond"cted, or where records,sust be kept under the conditions of this permit; b. Have access to and cop /, at reasonable times, any records that aust be kop under the conditions of this permits c. Inspect at reasonable time any facilities, equipent (incliding monitoring and control equipment), practices, or cperationa regulated or required under this permit; and d. sarple or monitor at reasonable times, for the purposes of assuring permit expliance or as otherwise authorized by the clean Water Act, any substances or parameters at am Iccatien. SECTICH D. REPCRTING RD3JIRD1*r:5 1. Chance in Discharge 2e permittee shall give notice to the Permit Issuing Authority as soon as possible of any planned physical alterations or additions to the permitted facility. Notice is required only when: ne alteration or addition to a permitted facility may meet orn c! a. l the criteria for determining whether a facility is a new sourcer or b. Se alteration or addition could significantly change the nature or increase the quantity of pollutants discharged. 21s notificatica applies to pollutants which are subject neither. to effluent limitations in the permit, nor to notification requirernents under Section D, Paragraph D-10(a). 2. Anciefpated h wliane, We pemittee shall give advance notice to the Permit Issuing Authority of any planned change in the permitted f acility or activity which may result in noncorpliance with permit requirements. Any maintenance of f acilities, which might necessitate unavoidable interruption cd operation and degradation of effice.it quality, shall be scheduled during noncritical vater quality periods and carried out in a manner approved by the Permit Issuing Authority. e g

~ _ _ - l Part II Page II-8 3. Transfer of ownership er control A permit may be autcznatically transferred to another party if s a.

The permittee notifies the Permit Issuing Authority of the proposed transtet 4t least 30 days in advance of the prcposed tranafer date; b.

The notice includes a written estament between t$e existing and new I permittees ccntaining a specific date for transfer of permit responsibility, coverage, and liability between them; and c. The Permit Issuing Authority does not notify the existirq permittee of his or her intent to modify or revoke and reiswe the permit. If this notice is not received, the transfer is effective on the date specified in the agreernent mentioned in paragraph b. 4. Monitoring Reports See Part III of this permit. t 5. Additional Monitoring by the Permittee If the permittee monitors any pollutant more frequently than required by this i permit, using test procedures asprend under 40 CPR 116 Or as specified in this permit, the results of t.Js monitoring shall be included in the calculation ard reporting of the data submitted in the Discharge Monitoring Report (EMR). Such increased frequency shall also be indicated. 6. Averaging of Measurements calculations for limitations which require awraging of measurenents shall i utilize an arithnetic mean unless otherwise specified by the Permit Issuing l Authority in the permit. 7. Cmpliarce schedules Reports of compliance or nonecrpliance with, or any progress reports on, interim and final requirements contained in any ecmpliance schedule of this permit shall be sutsnitted no later than 14 days following each schedule date. Any reports of nonecepliance shall include the cause of noncorpliance, any 1 rarnedial actiona taken, ard the probability of smeting the next scheduled requirement. l l I j ,s

Part II Page 88-9 8. 'Nenty-Four Hour Reporting me permittest shall orally report any noncompliance wh2ch may ordanger health or the envirorment, within 24 hours frtsi the time the per aittee becernes aware of the ciretc. stances. A written sutriission shall also to provided within 5 days of the time the pernittee beceres aware of the circastances. We written autriission shall contain a description of the nonecrpliance and its cause, the period of nonecepliarce, including exact dates and times and if the ncnccrp11ance has not been corrected, the anticipated time it is orpected to continue, and steps taken or planned to reduce, elimirate, and prevent reoccurrence of the noncap11ance. Se permit Issuing Authority may wrbally waive the written report, on e case-by case basis, when the oral report is made. Se following violations shall be included in the 24 hour report when they might endanger health or the envirorsnents a. An unanticipated bypass which exceeds any effluent limitation in the petuit. b. Any upset which exceeds any eff.luent limitation in the pemit. 9. Other Nenecrv11ance 2e permittee shall report in narratin form, all instances of nerncryliance not previously reported under Section D, Paragraphs D-2, D-4, D-7, and D-8 at the time monitoring reports c.re sutrutted. We reports shall contain the information listed in Paragraph D-4.

10. Changes in Discharoes of Texie substances l

2e permittee shall notify the Permit Issuing Authority as soon as it kncvs or has reason to beliew: mat any activity has occurred or will occur which would result in a. i the discharge, on a routine or frequent basis, of any toxic substanca(s) (listed at 40 cm 122, Aspendix D, Table II and !!!) j which is not limited in the permit, if that dia:harge will exceed the higbest of the following 'rceification levels *: (1) One hundred micrograms per liter (100 ug/1): (2) 'No hurdred micrograris per liter (200 ug/1) for aerolein ab acrylonitrile fiw hurdred micrograru per liter (500 ug/1) for l 2,4-d(nitrophenol ard for 2 cethyl-4,6-dinitreyhenols and one l milligram per liter (1 mg/1) for anti:cnyt or (3) Five (5) times the maxint.n et:ncentration value reported for that ] pollutant (s) in the permit applicatica.

Part !! ~ Pege U-10 Bat any activity has occurred or will occur which wccid result in any b. discharge, on a non-routine or infrequent basis, of a toxic pollutant (listed at 40 CFR 122, Appendix D. Table II and III) which is not limited in the permit, if that discharge will exceed the highest of the following ' notification levels's (1) Five hundred micrograns per liter (500 ug/1);

(2) One milligram per liter (1 mg/1) for antinnyt or

~ 'Mn (10) times the maximsa correntration val,ue reported for that (3) pollutant (s) in the permit ap lication.

11. Duty to Reapply If the 7ermittee wishes to continue an activity regulated by this petuit after the exp:, ration date of this permit, the permittee sust apply for and obtain a i

new permit. ne aplica*. ion should be tAitmitted at least 180 days before the expiration date of this permit. Se Permit Issuing Authority may grant permission to suknit an application less than it0 days in advance but ret later i than the permit expiration date. Issuirq Authority, the terms and crmlitions of this Where EPA is the Permit permit are autenatically continued in accordance with I of the permit and the Permit Tasuing Authority is unable throqh no fault 7 permittee to issue a new permit before the expiration date. j I

12. sia'natory Requirements All a plications, reports, or information sulaitted to tN Permit Issuing 3

Authority shall be signed and certified. i J All permit aplications shall be signed as follows: ) a. For the For a corporation by a responsible corporate officer. 1 l (1) purpose e4 this section, a responsible corporate officer reans: of the (1). a president, secretary, treasurer or vice president corporation in charge of a principal business fuaction, or any other person who performs similar policy - or decision-esking functions for the corporation, or (2) the wanager of one or mre i manufacturing productico or operating facilities erfloying rcre 250 persons or having gross annual sales or expendigures i exceeding 25 million (in second quarter 19d0 dollars), if I than l authority to sign documents has been assigned or delegated to the

l manar3er in accordance with corporate procedures.

(2) For a partnership or sola proprietorship by a getwral partner or l f the proprietor, respectivelys or by For a municipality, State, Federal, or other public agency: either a principal executive officer or rar. king elected of ficial. (3) All reports reqaired by the pemit ard other infomati l b. tN Ternit A prsen above or by a duly authorized representative of that peson. is a duly authorized representative only ift l

Part II Pege II-11 (1) Se authorization is made in writing by a person described aboves (2) ne authorization specifies either an irw*ividual or a position having I;esponsibility for the overall operation of the. regulated facility or activity, such as the position of plant manager, operator of a wil or a well field, superinterdent, posit.icn of equivalent responsibility, or an individual or position having overall responsibility for envitorynental matters for the corpany. (A duly authorized representative swy thus be either a named individual or any irdivital occwying a named position.): (3) The written authorization is suknitted to the Permit Issuing Authority. c. Certification. Any person signing a document under paragraphs (a) or (b) of this section shall maka the following ceetification: 'I certify under penalty of law that this document and all atta:hments wre prepared under the direction or supervision in accordance with a systen designed to assure that qualified personnel pecperly gather and evaluate the information autuaitted. Based on ny inquiry of the person or persons who manage the system, or those persons.directly responsible for gathering the information, the information subnitted is, te the best of my knowledge and belief, true, accurate, and ccrplete. I am aware that there are significant penalties for suinitting false information, including the possibility of fine and imprisorsnent for knowing violations.' 13, Availabtlity of Reports Except for data determined to be confidential under 40 CFR Part 2, all reports prepared in accordance with the terms of this permit shall be available for Nblic inspection at the offices of the Pe'nait Issuing Authority. As required by the Act, permit asplications, permits and offluent data shall not be considered confidenttal.

14. Penalties for Falsification of Reports de clean Water Act provides that any person who knowingly sakes any f alse statenent, representation, or certification in any record or other deemerit sdnitted or required to be maintained urder this permit, includirs renitorirn reports or reports of compliance or nonecepliance shall, upon conviction, be Wnished by a fine of not scre than $10,000 per vioP tien, or by irprisonment for not more than 6 scmths per violation, or by both.

stenct E. Dr.FINIUCNS 1. Per-it Israir1 Authority We Regicnal A61nistrator of EPA Region IV or his designee, unless at sone ti.me in the future the State receives authority to a61nister the b7 !S pt: gram and assumes jurisdiction over the permits at which tLme, the Director of the State prcgram receiving authori:ation beccres the issuing authority.

Part !! Page !!-12 2. Act 'Act' means the Clean Water Mt (formerly referred to as the Federal Water Pollution Control Act) Public law 92-500, as amended by Public law 9'r-217 and Public Law 95-576, 33 U.S.C. 1251 et seq. 3. Mass / Day Neasurenants a. De 'awrage monthly discharge' is defined as the total maas of all daily discharges saryled and/or measured during a calendar month on which daily discharges are sarpled and measured, divided b/ the ramber of daily discharges mappled and/or measured during such month. It is therefore, an arittretic mean found by adding the weights of the pollutant found each day of the month :nd ti.*n dividing thf s sum by the ntster of days the tests wete reported. Trea limitation is identified as ' Daily Awrage' or 'Honthly Average' in Part I of the permit and the awrage monthly discharge value is reported in the

Awrage' colum under '02antity' on the Discharge Monitoring Report (IHL).

b. Se 'awrage wekly discharge' is defined as the total mass of all daily discharges sampled and/or measured during the calendar week on which daily discharges are sampled and measured, divided by the ntsnber of daily discharges sappled ard/or measured during such week. it is, therefore, an arittsnetic mean found by adding the weights of pollutants found each day of the wek and then dividing this suri by the ntrter of days the tests were reported. 21s limitation is identified as ' Weekly Anrege' in Part I of the permit and the i average weekly discharge value is reported in the 'Maxirum' colum under '02antity' on the DMR. c. Se "maximo daily discharge' is the total mass (weight) of a pollutant discharged during a calendar day. If only one aarple is taken during arty calendar day the weight of pollutant calculated f rcri it is the 'maxirs.n dail7 discharge'. 21s limitation is identified as ' Daily Maximum', in Part I of the permit ard the highest such i i value Tecorded during the reporting period is reported in the 'Maximm' coltar, under '02antity' on the EHt. I d. Se 'awrage annual discharge' is defined as the total mass of all daily discharges sangled and/or measured during the calerdar year on I which daily discharges are sarpled ard measured, dividA by the ntamber of daily disenarges sarpled ard/or measured during such year. It is, therefore, an arithmetic mean fourd by aMing the weights of pollutants fourd each day of the year ard then dividing this sum by the ntrier of days the tests were reported. 21s limitatien is defined as 'Mnual Avdrage' in Part I of the permit ard the average annual discharge value is reported in the 'Awrage' coltron under '02antity" on the DMR. 2e DMR for this report shall be sutnitted in January for the previous reporting calerdar year. l 1 ,m-

Part 12 Page II-13 i 4. concentration Measurenwnts a. me ' average senthly concentration', other than for focal colifom bacteria, is the sum of the concentrationu of all daily discharges sa@ led and/or measured during a calerdar mcoth on which daily i discharges are samled aM seasured, divi.ded by the isster of daily . discharges sagled and/or sensured Juring such month "arittanetic mean of'the daily concentration values). We daily concentration value is l equal to the concentration of a corposite samle or in the case of grab samles is the arittunetic mean (weighted by, flow value) of all the mapples collected during that calendar day. Se awrage monthly count for focal coliform bacteria is the gocenetric mean of the counts for s&gles collected during a calendar month. 21s limitation ic identified as ' Monthly Aw rage' or ' Daily Aw rage

under 'other Limits
in Part I of the permit and the awrage monthly concentration value is reported under the ' Average' coltam under 'Oaality' on the CHR.

b. Se 'awrnge weekly concentration', other than for focal coliform bacteria, is the sun of the concentrations of all daily discharges repled and/or measured during a calendar week.on which daily discharges are sampled and measured divided by the ntster of daily discharges sospled and/or sensured during such week (arittsnetic sean of the daily cornentratien values). Se daily concentration value is equal to thw concentration of

cegosite sarple or in the case of grab samles is the arittsnetic sean (weighted by flow value) of all the sagles collected during that calendar day.

De awrage wekly cour't for focal coliform bacteria is the gemetric mean of the counts for samples collected during a calendar week. 'this listitation is identified as

Weekly Awrage' under 'other Li::its' in Part I of the permit aM the awrage weekly concentration va\\ue is reported under the 'Maximan' colan under 'Oaality' on the tem.

c. Se *maximam daily concentration' is tne concentration of a pollutant discharge during a calerdar day. It is identified as ' Daily Maxirum' under 'Other Ltaits' in Part I of the permit and the highest such value recorded during the resorting period is reported uMer the 'Maximasa' colusm unSer 'osality' on the DMR. d. De 'awrage armual concentration *, other than for focal collform bacteria, is the sum of the concentrations of all daily discharges saqled and/or seatured during a calendar year en which daily discharges are sa@ led aM measured divided by the number of daily discharges sarpled and/or measured during sach year (arithmetic mean of the daily concentration values). Se daily concentration value is equal to the concentration of a ccrposite sarple or in the case of grab samles is the arithrwtic mean (weighted by flow value) of all the sa ples collected during that calendar day. Se awes;e yearly count for fecal coliform bacteria is t.be ge<netric mean of the counts

Part II Fa3e 21-14 for samles collected during a calendar year. This limitation is identified as ' Annual Average' under 'Other Limits' in Part I of the permit and the average annual concentration value is reported under the ' Ave rage

colen under 'Oaality' on the DMR.

Tne IHR for this report shall be dubmitted in January for the previous reporting year. e-5. Other Measurements 3 a. The affluent flow arpressed as M / day (MGD) is the 24 hour awrage f1w awraged sonthly. It is the aritivnetic mean of the total daily flows recorded during the calendar month. Where sonitoring requisements for flow are specified in Part I of the perrd'. Os flow rate wlues are reported in the 'Awrage' coltam under 'C act/* on the IMt. b. An ' instantaneous flow measurement' is a unsure of flew tuen at the time of

sagling, when both the sagle and flow will be representative of the total discharge.

c. Where sonitoring requiremnts for ps, dissolved orygen or fecal coliform bacteria are specified in Part I of the permit, the values ere generally reported in the 'Ipality or concentration' column on the DMR. 6. Types of sareles i s. Corposite samle: A 'comosite samle' is a certination of not less than 8 influent or effluent portions, of at least 100 m1, collected i owe the full time peried spoeffied in Part I. A. The ccrTesite i sa@le sust be flow proportioned by either tine ir..arval betwen each j aliquot or by volume as it relates to effluent flow at the time of Aliquota any be collected penually or autcznatically. previous aliquo sa@ ling or teaal flow Jinco collection of the l b. Grab Sa g les A ' grab samle' is a single sn tent or effluent portion which is not a caTosite samle. The sagle(s) shall be collected at the perioS(s) most representative of the total discharge. 7. Calculation of Means of values is tb a. Arithmetic Mean: Tw arith.wtic swan of any set i sumation of the individual values divided by the neber cf i irdividual values. th b. Gecretric Mean: The georutric mean of any set of values is the N I root of the product of tha individual values where N is equal to the 1 neber of irdividual values, the gecretric near is eqaivalent to the antilo; of the arittrutic rean of the lojarittrts of the irdividual values. For purposes of calcolatirs the gecretric nean, values of zero (0) shall te censidered to be one (1). i t 4 1

4-+ l Part !! page !!-15 c. Neighted by Flow Values leighted by flow value means the summation s of e sob ooncentratten times its respective flow divided my th e summation of the respective flows. 8. O t tadefJh.g A calendar day is definud as the period in os aidnigh t of one day untti sienight of th e neat da*. Bow ever, for purposes of this permit, any / conseewtive 24-hour period that reasonnely represents the salendar day may be used for sampling. 9. Essardous Substance A hasardous s ubstance means any substance designated under 40 CFR part 116 pursuant to section 311 of the Cean mater Act.

10..bute Pollutant A toxic pollutant is ary pollutant listed as toxic under Section 307(a)(1, of th e mean un te r Act.

J l l 1 i l \\ l t i. 1 I 1 i l l I j t 4

PART III i Page I82-1 Permit No. FL0000159 CTIMER REQUIRDiDTIS A. Poporting of Monitoring Results Monitoring results obtained each calendar 'enth shall be sumnarized for that month and reported on a Discharge Monitoring Report Fom (EPA No. 3320-1), postmarked no later than the 28th day of the month following the ccinpleted calendar month. (For example data for January shall be submitted by February 28. ) Duplicate signed copies of these, and all other reports required by Section D of Part II, Reporting Requirernents, shall be submitted to the Permit Issuing Authority at the following addresses: Envirorrnental Protection Agency Florida Department of Envirorrnental Region IV Regulation Facilities Performance Branch Southwest District Water Management Division 4520 Oak Fair Blvd. 345 Courtland Street, N.E. Tampa, FL 33610 Atlanta, Georgia 30365 B. Reopener Clause This permit shall be modified, or alternatively revoked and reissued, to cceply with any applicable effluent standard or limitation issued or approved under Sections 301(b)(2)(C), and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent standard or limitation so issued or approved:

1. Contains different conditions or is otherwise more stringent than any ef fluent limitation in the permit; or

2. Controls any pollutant not limited in the pemit.

The permit as mcdified or reissued under this paragraph shall also contain any other requircrents of the Act then applicable. C. Definitions

1. "Calendar day" for the purposes of ficw ard temperature measurement is frcn midnight to midnight.

2. "Continuous" measurcrent frequency is defined as reasurements taken at intervals of no greater than one hour each, except for Tro, which shall be taken at intervals of no greater than one per 10 minutes.

3. "Total residual oxidants" or "TRO" is defined as the value obtained using the ampercretic titration mothed for total residual chlorine described in 40 CFR Part 136.

4. "Multiple grabs" for total residual oxidant analysis is defined as sampics taken at intervals of no greater than ten minutes over the entire pericd of chlorine addition and TIO discharge.

5. "Three-hour rolling average" for tegerature reans the average of the rest recent value with those values collected over the previous 180 minutes.

6. "Director" meanc the EPA Director of the Water Management Division.

7. "N/A" means no limitations, monitorirn, or reporting require: rents are applicable.

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y

~ , i. PART III Pag 2 III-2 Permit No. FL0000159 D. Polychlorinated biphenyl Compounds @ere shall be.w discharge of polychlorir"<d biphenyl ccepcunds such as those commonly used for transformer fluid. E. FIFRA Registered Ccmpounds Discharge of any product registered under the Federal Insecticide, Fungicide, and Bodenticide Act to any waste stream which may ultimately be released to lakes, rivers, strears or other waters of the United States is prohibited unless specif-ically authorized elsewhere in this permit. Bis requirement is not applicable to products used for lawn and agricultural purposes. Discharge of chlorine frca the use of chlorine gas, sodita hypochlorite, or other similar chlorination campennds for disinfection in plant potable and service water systems and in sewage treatment is authorized. F. Toxic Ccrnpounds The permittee shall notify the Director in writing not later than six months prior to planned use and discharge of any chemical, other than chlorine or other product previously reported to the Director, which may be toxic to aquatic life. Such notification shall incitde:

1. Name and general corposition of the chenical,

2. Frequencies of use,

3. Quantities to be used,

4. Proposed discharge concentrations, and

5. EPA registration number, if applicable.

G. Prohibited Plant Discharges Except as specifically permitted for 003, 006 and 007, there shall be no point source discharge of the following categories of wastes to waters of the United States or to any waste stream which enters such waters: low volume wastes (including, tut not limited to, boiler blowdown, wet scrubber air pollution control systers, ion exchange water treat:nent systens, water treatment evaporator blo',down, laboratory and' sampling strea:rs, floor drainage, ccoling towr basin cleaning wastes and blowdown frcm recirculating house service water systers), netal cleaning wastes (cleaning ccepounds, rinse waters, or any other waterborno residues derived frcm cleaning any metal process equipnent including, but not limited to, boiler tube cleaning, boiler fireside cleaning and air preheater cleaning, and specifically includirg such water tash operations as hosing dcwn boiler fireside surfaces), and sanitary wastes. Event recorders shall be placed at all overflow points frcm evaporation / seepage ponds receiving such wastes to assure ccrnpliance with this requirement. H. Ihrge Irading and Unloading Facilities We permittee shall operate and maintain barge loading and unloading facilities in such a msnner so as, to the the maximum extent practicable, preclude spillage of coal, chemicals, etc. used at the facility, and shall take all actions neces-sary to clean up and control any such spill which may occur.

PART III Pags III-3 Parmit No. FL0000159 I. Floating Materials _ The pemittee shall report all visible discharges of floating materials, such as ash or an oil sheen, to the Director when submitting EMR's. J. Erodable Material Storage The pemittee shall not store coal, soil nor other similar erodable materials in a manner in which runoff is uncontrolled, nor conduct construction activities in a manner which produces uncontrolled runoff unless such uncontrolled runoff has been specifically approved by the Director. ' Uncontrolled' shall mean without sedimentation basin or other controls approved by the Director. This yrmit may be nodified to include limitations for the discharge frcru such facilities, when installed. i K. Fish Hatchery Permittee shall provide up to seven million dollars to construct and operate for the remsining life of Units 1, 2, and 3 a fish hatchery as idicated it Part I.B.1.b, Schedule of Ccrnpliance. A Technical Advisory Ccmnittee (TAC) shall be established to review reports and offer stggestions on necessary actions. Copies of reports and other docunents noted herein shall be provided to the Director, State Director, and TAC members. A three-year plan and bu$get shall be developed by the pemittee acting on the advice of the TAC by the start of hatchery opera-tion. Permittee shall annually develop a detailed plan and operating budget for hatchery operation durirg the follcwing year and update ti.e three-year plan by the end of Novenber, acting on the advice of the TAC. Reports of hatchery activi-ties and progress over the previous year shall be subnitted annually, by the end of March. L. PSD Application Not later that eight months af ter issuance of this permit, permittee shall subnit a ccenplete application for a PSD permit to the Florida Department of Envirotraental Regulation with a copy to EPA. M. Ccndenser Cooling Water Flow Verification On conpletion of the helper cooling towers, pemittee shall accurately measure condenser cooling water ficws frcm Units 1, 2, and 3 to verify (within statistical accuracy) that the combined condenser flow dces not exceed 1,318,000 gallons per minute during the period of May 1st through October 31st of each year nor 1,120,300 gpn durirg the remainder of the year (see Part I. A.3, Page I-3). A report deconstrating ccenpliance shall be submitted not later than sh months af ter implementation of tower operation. Should permittee propose to modify the condenser ecoling water punps or systems, the Director shall be notified not less than three conths prior to such proposed modification. Upon notification by the Director, perrittee shall conduct additional flow verification studies and report results as required by the Director. N. Discharj;;e Temperature Monitoring On ecnpletion of the helper cooling tcwers, pemittee shall evaluate temperatures in the plant discharge canal in the vicinity of the intersection of the discharge canal and the original bulknead line to determine the most apprcpriate location

PART III Paga III-4 Pemit No. FIA000159 and system design for monitoring plant discharge tenperature. he evaluation shall include all plant operating modes and tidal conditions. A report shall be provided within six nonths following implementation of tower operation indicating proposed modifications to the present discharge tenperature monitoring system, if any. Necessary modificationa shall be ccupleted within three months using existing thermal sensors to the extent practicable. Additional equignent, if needed, shall be installed within one year. O. Seacrass Monitoring and Planting Following ccmpletion of the helper cooling towers necessary to meet the temper-ature requirements established in Part I. A. 3, Page I-3, for OSN 001, 002, and 005, pemittee shall monitor natural seagrass recovery, conduct experimental sprig planting, plant seagrass if natural recovery is not adequate, and report on this progran as indicated in Part I.B.l.f, Schedule of Compliance. A Technical Advisory Ccumittee (TAC) shall be established to review reports and offer sugges-e tions on necessary actions. Reports shall be subnitted to the Director, State Director, and TAC members. Biological studies shall be conducted during the two years following tcwer ccepletion to quantify seagrass presence and recovery. Ualess acceptable levels of natural seagrass recovery occur, pemittee shall cenduct multi-species sprig planting as recomended by the TAC during the third spring following ccepletion of towers and shall monitor the growth of planted seagrasses and the continued natural recovery for two years. If acceptable levels of natural recovery have not cccurred by the sixth spring follcuing cceple-tion of the tcwers and if experimental sprig planting has proven successful, pemittee shall plant seagrass in area (s) of approximately 10 acres per year as reccomended by the TAC. 'Ihis seagrass planting may be terminated should seagrass recovery be deemed to be at an acceptable level or if continued seagrass planting is considered to be infeasible by the TAC. P. State Certification The State of Florida Department of En71rermental Regulation has certifled the discharge (s) covered by this pemit with conditions (Attachnent B). Section 401 of the Act requires that conditions of certification shall beccrne a condition of the pemit. 'Ihe monitoring and sampling shall be as indicated for those parameters included in the cortification. Any effluent limits, and any additional requirments, specified in the attached state cerification which are more stringent, supersede any less stringent effluent limits provided herein. During any time period in which the more stringent state certification effluent limits are stayed or incperable, the effluent limits provided herein shall to in effect and fully enforceable. 6

l . to i Pa rt IV Pege IV-1 PAP.T IV BEST MANAGI24C{T IRACTICES CDtOITIOtG SECI' ION A. GDIERAL CONDIT!O!G 1. BMP Plan For pirposes of this part, the terms ' pollutant' or ' pollutants' refer to any substance listed as toxic under section 307(a)(1) of the Clean Water 3 Act, oil, as defined in' Section 311(a)(1) of the Act, and any sutstance listed as hazardous under section 311 of the Act. Se permittee shall develcp and implement a Best Management Practices (BMP) plan which prevents, w minimizes the potential for, the release of pollutants frcm ancillary activities, including material storage areas; plant site runoff; in-plant transfer, process and material handling areas; loading and unloading operations, and sludge and waste disposal areas, to the waters of the United States through plant site tunoff s spillage or leaks; sludge or waste disposal; or drair ye from raw material storage. 2. Imolementation 2e plan shall be developed with!n six months after the effective date of this permit and shall be imple:nented as soort.1s practicable but not later than 18 renths after the effective date of this permit condition unless a later date is specified by the Director. 3. General Recuirements me BMP plan shall: a. Be dccumented in narrative form, and shall include any necessary plot plans, drawings or maps. b. Establish specific objectives for the control of pollutants. (1) Each facility component or system shall be examined for its potential for causing a release of significant a.cunes of pollutants to waters of the United States due to equipment failure, inproper operation, natural phenonena such as rain or snowfall, etc. (2) Where experience indicates a reasonable potential for equipment failure (e.g., a tank overflow or leakage), natural condition l (e.g., precipitation), or other circumstances to result in l significant a:nounts of pollutants reaching surface waters, the plan should include a prediction of the direction, rate of flow, and total quantity of pollutants which could be discharged from the facility as a result of each cendition or circumstance, i s

t. Mrt W Mge IV-2 c. Establish specific best ranagement practices to meet the cbjectives identified under paragraph b of this section, addressing each component or system capable of causing a release of significant i amounts of pollutants to the waters of the United States, and identifying specific preventative or remedial measures to be implemented. d. Include any special conditions established in Se:tien B of this part. e. Be reviewed by plant engineering staff and the plant manager. 4. _ Documentation 2e permittee chall raintain the BMP plan at the facility and shall.Take the plan available to the permit issuing authority upon request. 5. BMP Plan Modification he permittee shall aand the BMP plan whenever there is a change in the facility or change in the operation of the facility which raterially increases the potential for the ancillary activities to result in a [ discharge of significant amunts of pollutants. 6. Modification for Ineffectiveness If the BMP plan proves to be ineffective in achieving the general objective of preventing the release of significant amunes of pollutants to surface waters and the specific objectives and requirements under paragraphs 6 and c of Section 3, the permit shall be subject to modification pursuant to 40 CFR 122.62 or 122.63 to incorporate revised BMP requirements. Any such permit modification shall be subject to review l in accordance wi':h the procedures for evidentiary hearings set forth in 40 CFR Part 124. [ SECTION B. SPECIAL CDtOITIO!:S t i WNE. 1 a l i f L a t 4 1 [ ---tv--, _vgw+r-- -rm%.,, ,,--e--,,m-,---w

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32399-2400 Bob Martancz, Governor aR Da:e Tmachtmann. Seercury John Shearer. Assisun: Secteury July 20, 1988 4 Bruce R. Barrett Director, Water Management Division 345 Courtland Street, N.E. Atlanta, Georgia 30365 Dear Mr. Barrett Following your request of April 14, 1988 and pursuant to Section 401 of the Federal Water Pollution Control ACT as amended (33 USC 1251, 1341), the Department hereby issues a state certification to: Florida Power Corporation (FPC) FL0000159 r'ystal River Power Plant, Units 1,2, and 3 c.trus County an applicant for a National Pollutant Discharge Elimination System (NPDES) permit. The. state certification is issued based on the following factors: A. The applicant is an authorized discharger under applicable state laws and regulations and currently holds a valid state permit authorizing discharge to the Gulf of Mexico. This state permit is identified as 1009-100280 which expires December 31, 1988. The applicant has two additional state permits, identified as I009-80908 and 1009-82180, authorizing dischargers from the ash ponds into the discharge canal. These permits expire on March 31, 1989 and August 31, 1989 respectively. B. Crystal River Power Plant Units 1,2 and 3 are existing dischargers. Unit 1 began commercial operation in October 1966; Unit 2 in November 1969 and Unit 3 in March 1977. The thermal component of the discharges from these three units is subject to compliarce with Florida Water Quality Standards. Section 17-3.050 of the Flos if a Administrative Code (F. A.C. ) provides that heated water discharges "shall not increase the temperature of the RBW [ receiving body of water) so as to cause substantial damage or harm to the aquatic life or vegetation therein or interfere with the beneficial uses assigned to the RBW." Section 316(a) of the Clean Water Act (the Act) allows the Regional Administrator to impose alternative and less stringent thermal limitations after demonstration that the water quality standards limitations are more stringent than necessary to assure the protection and propagation of a balanced, indigenous population of shellfish, fish, and wildlife in and on the receiving water. FPC filed an l

ATTACHME!TT B

98 0 4 Bruco R.

Bntrott July 20, 1988 Page Two application unA.er Section 316 of the Act and subsequently conducted an asproved biological study in an attempt to demonstrate a variance from the Florida Water Quality Standards should be granted. Section 17-3.050 F.A.C. authorizes the state proceedings for this demonstration to be conducted jointly with those of the federal government under 316(a) of the Clean Water Act. C. On December 18, 19 86, EPA issued a public notice of tentative determinations that the thermal discharge from Units 1,2, and 3 had caused substantial damage and that, therefore, in accordance with Section 17-3.05(1)(a)(3) of the F.A.C., appropriate NPDES permit limitations on the thermal component were those consistent with off-stream cooling. Such limitations would satisfy requirements of both the Florida Water Quality Standards and Sections 316(a) and (b) of the Act. EPA and the Department jointly conducted two public hearings in February 1587. At that time, FPC proposed to extend the discharge canal into deeper water as an alternative to off-stream cooling facilities. On March 1, 1988, FPC offered a second proposal including the construction of helper cooling towers. Under this proporal, the plant discharge temperature will not exceed 96.5' Fahrenheit (as a three-hour average) nor an instantaneous maximum temperature of 9 7.0*F at any time. FPC also proposes a 10 percent reduction in plant flow during the months of November through April, construction and operation of a fish hatchery,~and a program to monitor seagrass recovery and to plant seagrass if inadequate natural recovery occurs. D. In determining off-stream cooling or other approved alternate methods for reducing the thermal discharge, Section 17-3. 0 5 ( 1 ) ( a ) ( 3 ) F.A.C. requires the Department to consider the nature and extent of the existing damage, the projected lifetime of the existing discharge, and any adverse economic and environmental impacts. Based on this provision, the Department evaluated the FPC proposal of March 1, 1988 and supported it at the public hearing of June 22, 1988. Therefore, the Department concurs with the proposed NPDES permit conditions. E. On June 13, 1988, FPC filed applications for renewal of stace permits consistent with the provisions of the NPDES draf t permit and has petitioned the Department for a mixing zone for chlorine discharged from outfalls 001, 002, and 005 (condenser cooling water). FPC has also requested a mixing zone for oil and grease 4 -. - - - -,,,,, _ _ - - - - - = - n

Pga 3 of 4 Bruce R. Barrett July 20, 2988 Page Three discharged from Outfalls 004, 006 (which includes outfalls 003 and 007), and 009. The Department has determined FPC's request for mixing zones for chlorine and oil and grease to be appropriate. Upon its renewal, the Department will include in the state permit mixing zones for chlorine and for oil and grease which are contained in the attached Table 1 and are made part of this state certification. The Department concurs with the mixing zone provision contained in the draft NPDES permit for arsenic, iron, nickel, and selenium in the ash pond discharge outfalls 004 and 009. This mixing zone provision, which is in the current State permit, will be included when the state permit is renewed. The State of Fler.da certifies that on compliance with the above conditions, the facility will meet the provisions of Sections 301, 302 and 303, of the Federal Water Pollution Control Act as amended. This state certification will also be applicable to any subsequent changes to the draft NPDES permit so long as such changes do not cause the requirements to be less stringent than the state requirements as enumerated in Items B, C,D,and E above; however, the Department reserves the right to modify the effluent limitations placed on this facility pursuant to federal and state law, should further water quality analysis of the proposed discharge, its volume and character, together with the flow and characteristics of the receiving body of water, indicate that the discharge will not meet and comply with applicable water quality standards contained in Chapter 17-3, Florida Administrative Code. The correct address for submission of Florida's copy of the Discharge Monitoring Report ist Florida Department of Environmental Regulation Southwest District 4520 Oak Fair Boulevard FILING ANO AOKNOWLEDGEtSwvpa, Florida 33610 FILED, en tes ca:e, emsumt to S120 52 in er y 7 Florida Statuus, with the cesignated L cart. ment Clerk, re:eipt of which is here:y awnice E!/ /[ c ard .A Harve 7M,' d p* 'Chrk Date Deputy Director Division of Water Facilities ~ " "

RMH/mlj cc Dr. Patsy Baynard, FPC Dr. Richard Garrity, DER

I MTACHMENT B Pag) 4 of 4 Table 1 l Florida Power Corporation FL0000159 Crystal River Power Plant. July 20, 1988 Units 1, 2, and 3 Parameter (s) Outfall(s) Mixino Zone Chlorine 001, 002 and 005 700 feet downstream and 100 feet upstream from each Outfall i Oil and Grease 004, 006 and 009 400 feet downstream and 100 feet upstream from each Outfall Arsenic, ironf 004 and 003 400 feet downstream nickel, and selenium-and 100 feet upstream from each Octfall 9 .a-(

NCrTE: A DDUBLE BAR IN HIE RIGHT MAPGIN INDICATES DIAT A CHAtEE HAS BEEN MADE 'IO DIE DECGIBER 18, 1986, FACT SHEET IN DIE LINE SO DESIGNATED (cxclud;0 page number changes --> and changes to permit pages. ) MI!OR CliA!EES ARE UNDERLINED AISO. A single bar with asterisk indicates a change to the May 19, 1988, Fact sheet. FACT SHEET APRICATICt1 EOR twiONAL POLI 1TIAtTt DISCHAICE ELD 1INATICN SYSTEM PERMIT 'IO DISCHAPGE T8EATED WASTEWATER 'IO U.S. WATERS Application No: FL0000159 Ente: May 19, 1988 { Prcposed Permit Period: 5 years Ibvised: September 1, 1988 1. SYNOPSIS OF APPLICATICt1 i a. Nane and Address of Applicant Florida Pcwor Corpration Crystal River Power Plant P. O. Box 14042 EUR Units 1 - 3 St. Petersburg, Florida 33733 Citrus County, Florida b. Descri,ption of Applicant's Operation Generation, transmission, and distribution of electricity generally fal-ling under Standard Industrial Classification 4911. Plant fuel is coal (Units 1 and 2) and nuclear (Unit 3). c. Production Capacity of Facility Number of Units - 3 (Units 4 and 5 have a separate permit (FLOO36366)) Iargest Unit (megawatts - 890.5) Nameplate rating (megawatts - 1854.8) d. Applicant's Paceiving Waters Gulf of Mexico. For a sketch showing the location of the discharge (s), see Attachment A. e. Description of Existing Pollutico Abatement Facilities Once through conder.ser ecoling water for all throo units (Outfall Serial Numbers (OSN) 001, 002 and 005) and nuclear auxiliary ecoling water (OSN 006) is parM through bar racks and intake screens, chlorinated (except for OSN 006), and discharged to the site 'ischarge canal. Water used to ll sluice ash frca Units 1 and 2 is ttested in ash ponds (OS!1004 and 009) with effluent to the site discharge canal. Painfall runoff fran the coal pile is treated in a pond which infrequently discharges to adjacent tidal mrshes (CGN 008). Debris frce the intake is disposed of by landfill and wash water is returned to the plant intake canal (OSN 010A, 010B,_ and 011 serving Units 1, 2, and 3, respectively). Evaporation / percolation ponds are provided for all other wastes frcm Units 1 and 2. Non-radioactive wastes and radwaste fren Unit 3 (OSN 003 and 007) are treated (neutraliza-tion, settling, filtration and/or oil remvsi) and discharged to OSN 006. ICTE: 'Ihe radioactive cceponent of the Unit 3 discharges is regulated by the U.S. Nuclear Rgulatory Ccenission under the Atcnic Energy Act and not by the U.S.E.P. A. under the Clean Water Act. [

s. t Organism 96-hr Icnn (ug/1) Shore Crab 1418 Pacific herring 65 Atlantic Silverside 37 Tidewater Silverside 54 Shring 90 134 Shrimp (sand) Hermit' Crab 102 Hemit Crab 211 Naked goby 80 l* Stickleback, 'Ihreespine 167 Spot 90 Grass Shring 220 Selected organians do not include Mysidopsis bahia or similar fish food organisms, since these organisms could only be present in the site discharge canal after passage through the plant. ll (3) Limitation for _'IPO. For consistwncy with Florida Water Quality Standards requirements, TRO is linited to 50 ug/l (0.05 mg/1) in 001, 002, 005, 012, and 013. However, if no mixing zone is established by FDER, the limit will be 0.01 mg/1. Discharge of TRO is limited to 120 minutes per da.y to assure ccupliance with $423.12 and 423.13. l D. Intake Screen Backwash. No discharge of oil is pemitted, with no other limitations or monitoring required, based on DPJ. Iandfill disposal is required for the debris removed by bar racks and baskets. II. INTERIM LIMITATIONS OSN 001, 002, and 005 (once through cooling water frcm Units 1, 2, and 3, respectively) and 010A, 010B, and 011 (intake screen backwash) af ter ccopletion of the flow minimization system but before ccupletion of helper cooling towers (see pemit page I-2). A. Flow. See Item 6.b.I.A. B. Discharge Temperature. Unchanged frcm the previous permit. C. Teperature Rise. Unchanged frcm previous pemit. Individual unit tatperature rise limitations are deleted when the ficw minimiza-tion syst e is operational. D. Total Residual _ oxidants. Limited to 0.01/0.05 mg/1. Addition of chlorine is limited to two hours per day per unit. In a coce through cooling syste, time of addition is virtually equal to time of dis-l choge, but is easier to moni: >r. Also see Item 6.b.I.C. E. Intake Screen Backwash. See Its 6.b.I.D. l I i III. INITIAL LIMITATICriS C6N 001, 002, and 005 (once through cooling water frcm Units 1, 2, and 3, respectively) and 010A, 010B, a_nd 011 (intake i screen backwash) until impleentation of the flow mhimization system (see remit page I-1). 1 A. Flow. Ccmbined condenser ficw from Units 1, 2, and 3 is limited i to 1,318,000 g311ons per minute, the reported value. , s. B. Discharge Tenperature. Unchanged frcm the previous permit. ll C. Teperature Rise. Unchanged frcm previces pomit. D. Total Residual Oxidants. Limited to 0.01/0.05 mg/1. Addition of chlorine is limited to two hours per day per unit. In a once thrcogh cooling syste, time of addition is virtually equal to time of dis-charge, but is easier to nonitor. Also see Item 6.b.I.C. E. Intake Screen Backwash. See Item 6.b.I.D. ll IV. OSN 003 (an internal waste strem) - Iaundry and Shower Sump Tank discharge to OSN 006 (see permit page I-4). Limitations for O&G and TSS are as required by $423.12(b)(3) for "low voltane waste sources." Any treatment and discharge of "metal cleaning wastes" through this OSN is subject to total iron and total copper limitations as required by $423.12(b)(5) and 423.13(e). Limitations for pH are applie1 at OSN 006. V. OSN 004 and 009 - Ash Dond Discharges (see permit page I-5). ll A. TSS, O&G, and pH. Limitations for O&G and TSS are as required by S423.12(b)(4) for "fly ash and bottem ash transport water" and for O&G as required by FDER Pemits IOO9-80908A and IOO9-82180A. Modifi-cation dates for these permits are both December 24, 1987 and expira-tion dates are March 31, 1989 and August 31, 1989, respectively. Lim-itations for pH are as required by FAC $17-3.121. B. Toxic Substances and Water Quality Criteria (See It s 6.b.I.C(2). ~ Limitations consisistent with water quality standards criteria and the assigned mixing zone have been included in the pemit for arsenic, cadmitm, chrcmitm, copper, iron, lead, mercury, nickel, selenitm, and zinc as provided in FDER Permits IC09-80908A and IOO9-12180A. See Table I for a syncpsis of effluent data. VJ,. OSN 006 - Nuclear Services and Decay Heat Seawater System discharge ll to the Plant' Discharge Canal to the Gulf of Mexico (includes internal waste stre es OSN 003, 007, the Evaporator Condensate Storage Tank (ECST) discharge, the Condensate System (CD) discharge, and once thrcugh ecoling water) (see pemit page I-6). ll A. Total Residual Oxidants. Limited to 0.01/0.05 rg/1. Addition of chlorine is limited to that which is associated with OSN 005, since water for OSN 006 may receive sell amcunts of chlorine when OSN 005 is chlorinated due to the proximity of the ptmps for OSN 005 and 006. B. p]!. Limitations for pH are as required by FAC S17-3.121. ll C. Limitations for ECST and CD (internal waste strees). O&G and ll TSS are as required by S423.12(b)(3) for "low volume waste sources." Any treat.ent and discharge of "metal cleaning wastes" thrcugh this OSN is subject to total iron and total ecpper limitations required b/ S423.12(b)(5) and 423.13(e). Limitations for pH are applied at OSN 006. Note: 'Ihe radioactive ccrponent ec this discharge is regulated by the U.S. Nuclear Pegulatory Cceniss:3n under the Atcmic Energy Act and.

VII,. OSN 007 (internal waste strean) - Regeneration Waste Neutralization Tank (SETI-1). o OSN 006 (see pennit page I-7). Limitations for O&G and TSS are as required by 5423.12(b)(3) for "lo. volume waste sources." Any treata nt and discharge of "metal cleaning wastes" thrcuch this OSN is subject to total iron and total copper limitations required by S423.12(b)(5) and 423.13(e). Limitations for pH are applied at OSN 006. Note: 'Ihe radioactive caponent of this discharge is regulated by the U.S. Nuclear Regulatory Ccrmtission under the Atomic Energy Act and not by the U.S.E.P.A. under the Cleu Water Act. VIII. OSN 008 - Coal pile runoff (Units 1 and 2) to marsh area (s,ae permit page I-8). Limitation for TSS is as required by S423.12(b)(9) and (10). Iimitation for pH is as required by FAC S17-3.121. If. Stem water frcm diked petroletra storage or handling areas (see pemit page I-9). Requirements established by best professional judgement. 8 7. CHRONOWCY OF PEPMIT ISSUANCE /REIS3UANCE a. Initial permit issuance with expiration date of 02/18/80 - - --- 12/31/74 b. Pemit modification requiring conduct and reporting of biological studies in accordance with CWA 5316(a) and (b) ---- 07/09/79 c. Application for permit reissuance subnitted -------------- 08/30/79 d. Permit expiration (pemit remains effective until reissuance under the Administrative Procedures Act) ------------------- 02/18/80 e. Revised application and -' mary of changes --------------- 09/11/85 f. Biological report subnitted ------- ------------------ 01/31/86 g. FPC prcposal of mitigative measures only ----------------- 08/21/86 h. Public notice of tentative deteminations and preposed permit reissuance (required off-stream ccoling) --------------- he-12/18/86 Public hearing, Clearwater, FL (alternate prcposal to extend t 1. d isch a rge ca nal made by FPC ) ------------------------------- 02/03/87

j. Public hearing, Crystal River, FL (alternate proposal to extend the discharge canal made by FPC ----------------------------- 02/04/87 k.

Public notice extending canent period --------------------- 03/12/87 1. Additional information provided on the canal extension prcposal a s reques tcd by EPA a nd FDER -------------------------------- 04/17/87 m. Alternate prcposal subnitted by FPC (helper cooling tcwors to achieve 98'F discharge temperature, reduce plant intake ficv, and hatchery construction and operation)--------------------- 08/25/87 n. Additional information provided as requested by EPA and FDER - 01/27/88 o. Alternate prcposal mMified per EPA and GER concerns (discharge tmperature of 96.5'F (as 3-hcur average) and seagess monitoring / planting progran] 03/01/88 p. News release of EPA /FDER/FPC tentative agrecment on control measures to be required = -------------------------- 0 3/0 9/ 8 8 q. Pub l i c no t i ce -- ------- -------- ------ ------------------ --- 05/19/88 r. Public hea ring, Crystal Rivor, Florida ------------------------ 06/22/88 . i. TAB 2 1 CRYSTAL RIVER 121ITS 1 AND 2 l* Heavy Metals in Ash Pond Disch~arges Water Ash Pond Effluent OSN 009 (1) Quality No. Median Max. 2nd Criteria Parameter Obs. Value Value g (2) Arsenic, ug/l 16 35 147 104 50 (3),(4) ll Cadmita, ug/l 16 1 3 3 5 Chrmitn, ug/l 16 16 38 35 50 (3) Copper, ug/l 16 7 17 13 15 Iron, ug/l 16 355 440 380 300 (4) Lead, tg/l 16 <5 <5 <5 50 (3) Mercury, ug/l 16 <0.15 <0.15 <0.15 0.1 Nickel, ug/l 16 13 19 18 100 (4) Selenitn, ug/l 16 22 71 67 25 (4) Zinc, ug/l 16 45 59 59 1000 (3) (1) Data for the period April 1985 through July 1986. During this period, ash pond OSN 004 was not used. Heavy metals in OSN 004 will be similar during periods of operation. (2) Section 17-3.121, Florida Administrative Code, except as otherwise noted. (3) Section 17-3.061, F.A.C. (4) Applicable at the edge of the assigned mixirg zone. ll NCrrE Limitations for OSN 004 and 009 included in FDER Permits IOO9-80908A and IC09-82180A (and the redraf ted NPDES pemit) generally are those in the last column, above. Modification dates for these permits are both December 24, 1987, and expiration dates are March 31, 1989, and August 31, 1989, respectively.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV In The Matter Of ) NPDES Permit No. FL0000159 ) Florida Power Corporation ) Crystal River Power Plant ,) Findings and Determinations Units 1, 2, and 3 .) Pursuant to 33 U.S.C. $1326 Citrus County, Florida ) Statutory anb Regulatory Authority Section 301(b)(1)(c) of the Clean Water Act (CWA), 33 U.S.C. $1311(b)(1)(c), requires that National Pollutant Discharge Elimination System (NPDES) permits contain sufficient limita-tions ". ..to meet water quality standards, treatment stand-ards, or schedules of compliance, established pursuant to any Environmental Protection State law or regulations. Agency (EPA) regulations implementing the above statutory provision are found at 40 C.F.h 5122.44(d). Pursuant to the above authorities, EPA must apply the follow-ing requirements for thermal surtace water discharges found in 917-3.05(1) of the Florida Administrative Code (FAC) in issuing an NPDES permit, unless a variance is granted under 5316(a) of the CWA, 33 U.S.C. S1326(a), (see discussion below): (a) Heated water discharges existing on July 1, l_/ 1972: 1. Shall not increase the temperature of the RBW (receiving body of water] so as to cause substan-tial damage or harm to the aquatic life or vegetation therein or interfere with beneficial uses assigned to the RBW, 2. Shall be monitored by the discharger to ensure compliance with this rule, and 3. If the Department, pursuant to notice and oppor-tunity for hearing, finds by preponderant evi-dence that a cischarge has caused substantial damage, it may require conversion of such dis-charge to of f stream cooling or approved alternate methods. In makino determinations regarding such conversions, the Department may consider: ~/ The detinition of "existing discharge" found at 517-3.05 1 (1)(c)(iv) of the FAC includus any thermal discharge which was under construction or for which a construction or opera-tion permit was issued prior tc the effective date of the rule. G

t, a. The nature and extent of the existing damage; b. The projected lifetime of the existing dis-charge; c. Any adverse economic and environmental (in-cluding non-water quality) inpacts which would result from such conversion; and d. Such other factors as may be appropriate. Under S316(a) of the CWA, EPA may impose alternative effluent limitations with respect to the thermal component of a point .whenever the owner or operator of any source discharge stach source. .can demonstrate to the satisfaction of the Administrator. .that any effluent limitation proposed for the control of the themal component of any discharge from such source will require effluent limitations more stringent than necessary to assure the protection and propagation of a balanced, indigenous population of shellfish, fish, and wild-life in and on the body of water into which the discharge iS to be made. The CWA at 5316(b), 33 U.S.C. S1326(b), requires that the location, design, construction, and capacity of cooling water ir.take structures reflect the best technology available for minimizing adverse environmental impact. Factual Background On December 31, 1974, EPA issued a permit to the Florida Power Corporation (FPC) for its Crystal River Power Plant, Units 1, 2 and 3, which pemit required offstream cooling subject to consideration of a variance and alternative limits under 5316(a). Since the Agency found that adequate data were not available to determine whether alternative limits for the themal component could be

allowed, the 5316(a) determination was deferred pending the completion of adequate engineering and biological studios.

FPC requested an adjudi-catory hearing on the pemit in January, 1975. In settlement of the hearing request, EPA israed a modified permit on July 9, 1979, with an ef fective date of July 23, 1979 and an expiration date of February 28, 1980. The Florida Department of Environmental Regulation (FDER) certified the permi t on February 7, 1979. The modified pemit imposed a discharge flow limitation of 100 MGD subject to implementation or modification consistent with the Regional Administrator's final 5 316 detemination. (The current discharge is 1898 MGD). The pemit also contained a schedule of compliance which required, among other things, themal/ biological post-opera-tional monitoring (following the start-up of Unit 3) and b--

, r. 5316(a) and S316(b) studies. Further, the permit stated that (blaseo on these (5316(a) and $316(b)] smudies, the Regional Administrator shall make a determination as to the possible need for procedure modification, Jacility construction, re-duced thermal discharge or reduced intake flow." On August 30,

1979, prior to the expiratian bte of its modified permit, FPC submitted a permit. For;ewal appidet.tian to EPA.

Until now, EPA has not a9ted on that applications however, pursuant to the..dministrative Procedurtss Act,' the previous permit remain; ef fecti' e unti? F-t 7eisenes a pe:qh to FPC. In January 1985, FPC submitted its final report of the $316(a) and $316(b) studies which were required by its July 23, 1979, modified permit and which were co. ducted f rom Jm e 19 VI to August 1984. On September 11, 1985, FPC subm.cted a0 updated version of its August 30, 1979 renewal application. FP sub-mitted a proposal for certain mitigation measures on August 21, 1986. These included: creation of marshes, planting of seagrasses, construction and operation of a hatchery, and conduct of a monitoring program. On January 23, 1987, FPC submitted an alternative proposal to extend the existing discharge canal. Additional information regarding that pro-posal was provided on April 17, 1987. FPC proposed a second alternative plan on August 25, 1987 comprising the installa-tion of helper cooling towers 2/, reduction of intake flow and hatchery construction and operation. Additional informa-tion was provided on January 27, 1988, and the proposal was modified on March 1, 1988 to include a seagrass monitoring and planting program and a limitation on plant operations to maintain a three-hour average temperature not to exceed 96.5' F and an instantaneous maximum temperature not to exceed 97.0* F. f/ In the prcposed helper cooling towee system, a portion of the plant's heated effluent will be cooled and returned to the discharge canal where it will mix with the remainder of the uncooled ef fluent. In a recirculating (of fstream or closed cycle) cooling tower system, the entire volume of thermal effluent is cooled (with the exception of a relatively small amount of

blowdown", which is discharged to maintain an acceptable chemical equilibrium in the towers), recycled to the plant for reuse, and subsequently returned to the towers for additional cooling.

Recirculating cooling towers for Units 1, 2, and 3 would reduce the plant intake flow by approximately 85% (85% of the water is recirculated and 15% is evaporated or blown down). No reduction in intake flow occurs with the proposed helper cooling towers. e 4 W

. Findings of Fact and Determinations Pursuant to $316 of the CWA and under authority delegated by the Regional Administrator on March 15, 1985, the Director of the Water Management Division, Region IV, Environmental Protection Agency makes the following findings relative to the Crystal River Power Plant, Units 1, 2 and 3: 1. The Crystal River generating facility is located adjacent to Crystal Bay, an estuarine nursery area between the community of Crystal River and the Cross Florida Barge Canal. At this facility, the Florida Power Corporation operates five generating units. Historically these units were placed into operation in the following sequence: Unit 1, 1966 Unit 2, 1969 Unit 3, 1977 Unit 4, 1982 Unit 5, 1984 Units 4 and 5 employ closed cycle cooling with the use of natural draft cooling towers, whereas, Units 1, 2 and 3 each rely on once-through flow for cooling the condensers. 2. A combined daily flow of 2936 cfs (1898 MGD) is required for the cooling systems of the two coal-fired units (Units 1 and 2) and the nuclear unit (Unit 3). Approx-imately 50 percent of the total flow is directed tc the nuclear unit. Water for the once-through mode of opera-tion is drafted from an intake channel extending westerly into Crystal Bay. Separating the intake channel from the discharge area of the facility is a seven-mile long dike which flanks the northern side of the intake channel. This channel a.lso serves barge traffic for the delivery of coal to the plant site. Heated water from the conden-ser cooling systems is returned to the bay on the northern side of the seven-mile dike. 3. From June 1983 through August 1984, FPC conducted $316(a) and S316(b) studies according to a plan of study approved by EPA and FDER. The operational effects of Units 1, 2 and 3 on the marine biota of Crystal Bay were the subject of

hose studies.

4. Seasonally, the maximum temperature regime for the area of Crystal Bay supplying water for condenser flow occurred in mid-July to mid-August. Temperatures of inshore and offshore waters not impacted by the thermal plume at this time averaged about 86*F with maximum ranges of about 84.2'F to 89.6'F. Maximum average 24-hour discharge ternperatures at the point of discharge (POD) were in the range of 102.9'F to 103.8'F. l 4

f -S-8. A representative view of the plume dimension for the period of seasonally maximum temperature was depicted in the records of intensive temperature sampling of August 13, 1983. At this time Units 1, 2 and 3 were operating at 77 percent of maximum thermal output. The average 24-hour discharge temperature was 99'F. The seaward boundary of the' plume (8*/.8'F isotherm) extended approximately 2.8 miles offshore of the POD and en-compassed approximately 2100 acres (3.3 r.quare miles) of bay bottom. At 100 percent capacity, water tempera-tures within the 2100 acres of the plume would be equal to or greater than 91.8'F. 6. Seagrass and attached macroalgal communities were ad-p versely impacted by heated water discharges from Units j-1, 2 and 3. Within a 2-mile radius of the POD, an area of approximately 1100 acres of bay bottom was shown to be virtually barren of attached seagrasses and mdcroaloes. This area of severe thermal impact represented nestly a three-fold increase in the acreage of barren bay bottom since Unit 3 was placed into operation in 1977. 7. The benthic community of macroinvertebrates living upon and within the sediments of Crystal Bay were adversely impacted in a 3000-acre zone of the discharge area. The benthic impact was attributed to the followings a. Thermal stress; b. Reduction and loss of attached seagrass and macroalgal habitat; c. Siltation resulting from materials carried in the discharge plume as well as wind and discharge induced turbulence acting upon the bay bottom which has lost the stabilizing benefits of at-tached macroalgae and seagrasbes. 8. The Crystal Bay region associated with the power station was shown to be a spawning and nursery area for numerous species of fish and shellfish. These species included animals of recreational, commercial, and forage value. 4 i 9. Trawl and seine sampling studies show that during much of the year over 50 percent of fish and invertebrate j species normally indigenous to Crystal Bay are excluded l from the thermally impacted area. 10. Annual impingement of finfish and shellfish species l having recreational, commercial and/or forage value ap-i proximated 23 tons including 3 4 tons of pink shrimp and 14.3 tons of blue crab. No system is provided for the return of viable organisms to the bay. i f 1 . ma*

.- 11. The entrainment of fish eggs and larvae of fish and shellfish by Units 1, 2 and 3 was considerable. Annual entrainment involved billions of animals most ot which were anchovies and crustaceans, i.e. stone crab, Calli-nectes crabs, and penaeid shrimp. The Callinectes crab includes the commercially important blue crab and the penaeid shrimp classification includes the three commer-cially important white, brown, and pink shrimp. 12. The FPC modeling efforts to forecast the effects of entrainment on adult populations of fish and shellfish at large are flawed and provide an inadequate basis to judge the full impact of entrainment on fishery resources. 13. Section 17-3.05(1)(a) of the FAC is applicable to dis-charges existing on July 1, 1972 or under construction prior to that date. Units 1 and 2 were in operation on that date and Unit 3 was under construction prior to that date, therefore, that section applies to the Crystal River Power Plant discharge from those units. Based upon the above authorities and findings, I hereby deter-mine the following: 1. The 5316(a) and S316(b) studies conducted by FPC were sufticient to demonstrate significant adverse biological effects associated with the siting and operating of Crystal River Units 1, 2 and 3. 2. Approximately 3000 acres (4.7 square miles) of Crystal Bay are adversely affected by the thermal discharge from the facility. Within this 3000 acres, at least 800 acres (1.2 square miles) of seagrass and attached macroalgal communites have been destroyed because of the excessive temperatures created by the operation of Units 1, 2 and 3. An additional 300 acres (0.5 square miles) were barren at the start of the 5316 studies, all or a portion of which was due to the previous operation of Units 1 and 2. In addition, major components of locally indigenous fish and invertebrate species are excluded from the thermally inpacted area. 3. The 5316(a) study demonstrates that the existing thermal discharge has caused substantial damage in Crystal bay in violation of the FAC at S17-3.05(1)(a). The draft permit proposed on December 18, 1986 contained effluent limitations which were consistent with installation of an off-stream cooling system, such as recirculating cooling towers, on Units 1, 2, and 3. Those limitations would have assured compliance with the FAC and would have been consistent with $316(a). I

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. 4. The FPC proposal to instr.ll helper cooling towers will produce a maximum instantaneous discharge temperature of 97.0' F. and a maximum three-hour average temperature of 96.5* F. The helper cooling towers are expected to return the discharge area to the approximate thermal levels in existence prior to the operation of Unit 3 beginning in 1977. The thermal discharge f rom Units 1 and 2 is known to have impacted an area not greater than 300 acres of bay bottom. Based on an evaluation of new information submitted by FPC, I have tentatively determined that the thermal effluent limitations proposed in the December 18, 1936 draft permit wire "more stringent than necessary to assure the protection and propagation of a balanced indigenous population of shellfish, fish and wildlife in u and on the body of water into which the discharge is to be made. Accordingly, the previous tentative determination to deny the request for a $316(a) variance is hereby revised. 1 have tentatively determined that a variance for a 300-acre area would assure the protection and propagation of a balanced, indigenous population in Crystal Bay. 5. The level of entrainment and impingement demonstrated by the 5316(b) s tuti conrtitutes an adverse impact to the biota of Crystal Bay ad environs. The intakes of the Crystal River Power Plt.; are located in an estuarine nursery area. The capacit; 't Units 1, 2 and 3, based on a once-through cooling mood, is 2936 cfs (1898 MGD). There are no design features incorporated.in the facility which would minimize impact of the large volume of flow (capacity) and poor location. The

location, capacity and design of Crystal River Units 1,

2 and 3 do not reflect the best technology available for minimizing adverse impacts as required by S316(b) of the Clean Water Act. 6. Helper cooling towers will not reduce the present intake flow or the entrainment of aquatic organisms associated with that flow. However, the proposed reduction in plant intake flow during the months of November through April will proportionately reduce entrainment during that peri-od. Installation of closed cycle cooling towers would reduce entrainment damage by about 85 percent, however, the increased cost (about $150 million more that the system proposed by FPC) is considered to be wholly dis-proportionate to the environmental benefits to be derived. 7. To minimize the adverse impact of the Crystal River Plant intake structures, installation of fine mesh screens and a return mechanism (similar to that in operation at the Big Bend Station in Tampa) would constitute best available technology under $316(b) of the Act.

However, 4

% this modification is not considered to be technically feasible due to the use of the intake canal for coal delivery. Ambient silt from the Gulf of Mexico, which settles in the intake canal and is resuspended by coal barges, would collect on the intake screens (0.5 mm mesh would be necessary to remove fish eggs and larvae). Even if silt did not clog the screens and render them in-operable, return of the removed solids to Salt Creek (necessary for return of aquatic organisms at the Crystal River site) would cause unacceptable siltation in the small creek. 8. No other practical technological modification of the cooling water intake structures is available which would minimize the environmental impacts to an acceptable level. Therefore, I have tentatively determined that (1) reduction of plant flow by 15 percent during the months of November through April, in conjunction with, (2) construction and operation of a fish hatchery over the remaining operating life of the three units (in an attempt to replace fish and shellfish eggs, larvae, and juveniles entrained by the plant) will constitute minimization of the environmental impacts of the cooling water intake as required by Section 316(b) of the Act for the C rys tal River Power Plant, Units 1, 2, and 3. [, SEP 1 1998 DATE: YhUCE h. BARRETT, Director Water Management Division 4

September 1, 1988 RESPONSE: TO COtENTS CRYSTAL RIVER PCMER PIANT UNITS 1, 2, AND 3 NPDES NO. E7.4000159 I. Response to Permittee and Public Caments, June 22, 1988 Public Hearing 6 pages II. Response to Written Cannents 8 pages I i 6 L 5 e p k I I i i I 4 -...__...__-,._,..-.._9

September 1, 1988 RESPONSE TO PERMITIEE AND PUBLIC CCHME2fIS PUBLIC HEARING, JUNE 22, 1988 CRYSTAL RIVER PCMER PIMF UNITS 1, 2, AND 3 NPDES NO. FI4000159 1. Dr. Patsy Baynard, Florida Powr Corporation (FPC), Hearig Transc. ipt pages 12-18. A. pp 12-14. Intro &ction of self, responsibilit.ies for FPC, FPC service area, site location and unit description, and permitting history. Response Coments noted. B. p 14. Disagreement on study results: area affected, previous presence of 8 seagrass, absence of substantial damage, and sufficiency of existing permit limitations. Response: In terms of the area affected by the thermal pitane, the EPA estimate of 2100 acres is very conservative in favor of the power plant. Even a cursory examination of various data sets shows that the plume frequently enempasses I almat the whola area between the barge canal spoil islands and intake dike and extends westward beyond the westerimst end of the dike and spoil islands - an area in excess of 5000 acres. Furthermore, the data show that tenperatures exceeding the thermal death point of indigenous organisms enempass areas in excess of 3000 acres. l Furthernere, a 1972-1974 study (sponsored by FPC) clearly demonstrates the l presence of extensive acreages of seagrass and macroalgae in the discharge area prior to the operation of Unit 3. With the operation of Unit 3, nearly 800 acres i of seagrasses and meroalgae have been eliminated frcm Crystal Bay. FPC disagree-ment with the EPA determination of substantial damage is noted. i 1 C. pp 15-18. Described FPC prcposal relating to construction and seasonal r, ntion of helper coolirn towers (indicated possible locations and indica- .. n of no expected significant off-site salt drift effects), seaconal flew reductions, construction and operation of a fish hatchery, seagrass monitoring and planting program. Provided cost estimate of between $80 and 100 million. Response Ccrments noted. 2. Ms. Helen Spivey, President, Crystal River City Cconcil, speaking as a private citizen, pp 34-35. Asked questions relating to ecpper in cyaters, irpact of discharge on msnatees, and personal observations of "pigs" (mechanical conden-ser cleanirn balls) in the discharge area. Desponso: Answers provided by Mr. Charles Kaplan of EPA. 3. Mr. Dixie Hollins, Executive Vice President, Hollins Corporation, pp 37-39. A. pp 37-38. Introd;ced self and Corporate holdirgs and activities. Pospense Ccaments noted.

Juna 22, 1988 Haaring ~2-B. p 38. Indicated concern with salt water drift impacts on planted pines, hardwood hamnocks, magnolias, and other vegetation on the Hollinswood Ranch property over the long-term, rather than on short-term observations. Response: EPA has conducted an independent assessmentl of salt deposition inpacts and concluded that there should be no long term significant inpacts to the vegeta-tion. EPA evaluated vegetation types reported as ranging frca very tolerant to intolerant and divided into two plant ccumunity types: overstory/understory (e.g. live oaks, pine trees) and shrubs and herbaceous species (e.g. holly bush, marsh grass). We EPA analysis utilized a worst case scenerio which was nere critical than that used by FPC2 and assessed potential inpacts using short-term drift deposition rates (one to 10-day periods) as if they were occurring continu-ously over the entire fcur-month stamer period of helper tower operation. The majority or the species that make up the overstory/understory in the Crystal River site area are high and nederate cosisunce plants 71th the majority of the 2 icw resistance species located in the groundcover Aayer of the plant ccrrunity, This includes the areas containing planted pine, hardwood hanrocks, and magnolia. We Crystal River area contains a negligible mount of salt intolerant vegeta-tion 2, ne potential damage to vegetation has been divided into two types of damage; threshold damage and 50% leaf damage. nreshold damage is when the plant beiro impacted begins to show s!gns of stress. Threshold damage caused ty salt deposi-tion is difficult to identify in field studies because there are usually other sources of stress irpactirg the vegetation. We 50% Icaf damage level of stress caused by salt de;osition is evidenced by 50% of the leaves of the plants bei'vg draged. Necrosis is a ccamon a sign of salt damage. We planted pine located in areas that will receive salt depcsition frcm the cooliD2 tcwers have been identified as slasn pine 2 Salt sensitivity data on slash pino is not available; bcwever, Virginia pino is a moderate resistance species and pitch pine is a high resistance species 2 Se EPA assessnwnt assumod slash pine to be a mcderate resistance species. Salt sensitivity data is not available for magnolia trees. Hcwever, the physical characteristics (a tall plant species with waxy leaf surfaces and hard cuticlo) of magnolias are ccrmen to species with mcderate or high salt resistance 2 EPA assured magnolias to be a moderate resistanco species. Area I (See Figure 1) is a 15-20 acre portion of land that will receive the greatest salt deposition not on FPC prcporty. 20 vegetation in Area I is coastal and coastal hydric herock. We upper levels of vegetation in Area I are mostly high resistanco species. Ecse taller plants will receive the majority of the salt de;osition and will shield the low-lying vegetation frcm the salt deposition. no low resistance species are nest ecrmen in the gecondcover level of vegetation. The salt deposition has the potential of causing 50% leaf damage to Icw resistance species; however, the shieldirg effect of the tall vegetation will reduce the xcunt of salt deposited on the icw resistanco species and the associated danugo to those species. % ore auy be threshold damgo to mcderato resistanco species in Area I. Hcwevor, this potential darago shculd not be observable. A U.S. Enviremontal Protection Agency, of fice of Policy and Managcment, Fagion l IV, Assosment of Salt tbrosition Impsets at Crystal River, August 31, 1988. i l KM Engineerirn ard Applied Sciences, Inc., Envirorrental Asssestnent of Salt 2 Drif t Irpacts frce Florida Power Corporation Crystal River Plant, Juno 1980. s

Juna 22, 1988 Harring, The largest area of impact, Area II, is 250-300 acres that is ccuprised of plant ccm: unities that have an overstory/understory, except for the freshwater marshes. 1 The overstory/understory species, being taller than the groundcover vegetation, will receive a majority of the salt deposition, thus shielding the low-lying species. The salt deposition has the potential of causing 50% leaf damge to low l resistance species. However, the shielding effect of the taller vegetation will red. ice any potential impacts frcm salt deposition. here may be occasional threshold damage to moderate resistance species, although this damage should be i uncbservable. l There are about five acres of freshwater marshes in Area II that do not contain a i canopy and will receive the full salt deposition. Se Jptcies in the freshwater marshes are about one third of each low, moderate, and hMa resistance species. ne salt deposition may cause damage to the low resistance species which might i result in a shif t of the plant population tcward a higher percentage of more salt i tolerant species. Were should be no observable impacts north of Area II. ) C. p 38. Opined the need to extend the established FPC salt drift it. pact j mnitoring program onto Hollins prcperty to determine any build-up prior to { dacage beccmirg apparent. [ f Responso: Althcugh no impacts to soil and freshwater are expected, EPA plans to i modify the existing NPCES and PSD permits for Units 4 and 5 in the near future. FN will be required to increaso the nunber of deposition and vegetaticm monitor-1 ing stations included in the approved monitoring prcgra.n to include a representa-tive numler of hammek areas and freshwater carrhes. Se monitorirg program + 1 will also be mcdified to include initiation of soil and freshwater sampling l to establish basolir.e salt conc 9ntrations, measure future concentrations, and evaluate changes which could irpact vegetation prior to the irpacts toccming visibly evident. Additionally permit conditions will require FPC to continue its [ evaluation of impacts and to implement corrective actions if significant damage 1 i occurs. Such action eculd include the installation of more efficient drif t elim-l inators. l l D. p 38. Questioned who would be liable if damago occurred. Response: Florida Powr Corporation. i E. pp 38-39. Cpined that existing damage should be accepted rathor t.han risking thcusands of acros of forest. Response: Over 800 acres of aquatic habitat will be improved to reet Florida Water Quality Standards requirecunts by the proposed action. Potential, though r not expected to be otoorvable, irpacts to land offsite feca FM prcporty wuld i bo limited to an area of not rmre than 300 acres. he Clean Water Act (Ga) requires ccepliance with Florida Water Quality Standards, and EPA cannot issuo a pemit which will not rmot those stardards unless a variance is granted under Section 316(a) of the OA, which is applicable to therT al discharges only, hat I section provides that any alternativo limitations on tho thorn 11 cceponent of the dischargo must assure the protection and prcpagation of a talanced, irdigences j pcpulation of shellfish, firh and wildlife in and on the tody of water into which the dischargo is made. It fo11cws that EPA cannot issue a permit which dces not i address the damago caused by the dischargo. See, Dreision of the General Counsel

June 22, 1988 H uring No. 58, In Re Bethlehem Steel Corporation, March 29,1977 (the Administrator nust independently interpret and appfy state water quality stardards to ensure ccepli-ance with Section 301(b)(1)(c) of the CWA). EPA has tentatively detemined that the alternative thermi limitations associated with helper cooling towrs are consistent with Section 316(a) ard Florida Water Quality Standards requirements. Also see previous responses. 4. Ms, Virginia Splitt, p 39. Objected to hearing procedures which preclude the inmdiate resporse to questions. Fesponse: Opening statment by Mr. Bruce Barrett of EPA (as well as materials previously railed to Ms. Splitt) indicated that all ccennents and questions would be responded to in writing and distributed to hearing participants. 5. Mr. Richard Pilney, representing MinaSota-8E,, Inc. and Concerned Citizens of Citrus County, pp 39-41. A. p 40. Opined that the prcposal is more of an experirent than an assurance that it will work and that the proposed discharge tenperature will not assure that the grasses will recover. Resporse: he degree of habitat recovery associated with the installation of helper cooling towrs can not be precisely forecast. It is the EPA judgenent that with a reduction in the discharge temperature during the warner months, a significant recovery of habitat should occur. He redraf ted permit requires seagrass monitoring and replanting if inadequate revegetation occure. B. p 40. Cpined that closed-cycle cooling towrs would be a better solution to the probim due to reduction in intake ficw and associated intake impacts and also that mitigation by use of the fish hatchery ray not be legally permissable. Response: DA has tentatively determined that the alternative thermi limitations associated with helper cooling towers are consistent with section 316(a) and Florida Water Quali.ty Standards requirements and therefore, closed-cycle ecoling tow rs are not required for control of the therral ccryonent. EPA has also tentatively deternired that the costs asscciated with closed-cycle ecolirg tcwers are wholly dispr pcetionate to the environm ntal benefits to to derived, and that there is no other practical technological rodification of the ecoling water intake stru::tures available which would minimize the envirorrental impacts to an acceptable level. It has therefore teen tentatively determined that (1) reduc-tien of plant ficw by 15 percent during the months of tbvmber thrcugh A;,ril, in conjunction with; and (2) construction and cperation of a fish hatchery over the recaining cperating life of the three units (in an attecpt to replace fish and shellfish eggs, larvae, and juveniles entrained by the plant) will constitute minimization of the environrental irpacts of the cooling water intake as required by Section 316(b) of the CG for the Crystal River Power Plant, Units 1, 2, and 3. C. pp 40-41. Cpined that the da age caused by a spill at Cardinier did less da age to aquatic life than tne Crystal River Plant. Fossonse ReqJiremnts of Section 316 of the CWA are applicable to the therral discharge and intake irpacts of the Cristal River Plant and have teen follcwed in I arriving at the draf t remit conditions. Other sections of the the Cu are applicable to other types of waste discharges and spills.

i June 23, 1988 Hooring 6. Mr. David E. Walker, President, Citrus County Audubon Society, pp 41-44. A. p 41. Indicated personal observations of dead bottcm vegetation and need for power. Responses Cm ments noted. B. p 42. Expressed concern with damage to the estuary due to storm related spoil bank erosion, combined with thermal and other plant discharges. Noted his observations of fishing decline over the past nine years. Opined that elimination of the discharge canal alternate and the associated dredging and siltation impacts was a good decision, but that the "larger" tcwers would be the best proposal, but that the "smaller" towers would be better than nothing. I Expressed understanding and concurrance with Mr. Hollins' concerns relative to salt drift. Responses Cmments noted. See Response 5.B. C. p 42-43. Expressed doubt that seagrass can be restored at depths to ten feet. 7 Response Depths associated with restoration will typically be not more than i three to six feet, mean low water. D. p 4 3. Questioned the species of fish to be raised in the hatchery. 'Asponse A Technical Advisory Ccmittee will be established to provide reccreen-dations. E. p 43. Indicated confusion with the scurce of salt. . Response A smil quantity of the hot condenser cooling water which is cooled in i the cooling tower (generally about 0.001 to 0.005 percent) is entrained as very t .small droplets in the air as it contacts the water (to cool it) in passing through the ccoling tcwer. This water is discharged with the air at the top of the i cooling tower, At the Crystal River site the condenser cooling water is "salty" l since intake is frcm the Gulf of Mexico end therefore the water droplets going cut the tcp of the tower are "salty". F. p 4 3. Opined that our first priority must be the preservation of the natural resources. i Response Ccrxent noted. l 7. Carl Cervi, pp 43-45. Prcposed the installation of dilution pumps to pump water frcm the intake canal to the discharge canal to reduce the plant discharge temperature to an acceptable level.

Response

Increasing the flow of water (presently almst tw billion gallons per day) wculd also increase the number of smil aquatic organises that are killed by i passage through the new pumps and by contact with the hot water in the discharge canal. The existing accunt of damage to these organisms has already been deter-mned to be at an unacceptable level and F7C will be seasonally reducing the [ plant intake ficw in order to reduce the present level of damage. Increasing the f intake ficw and associated damge is not an acceptable solution to the Crystal [ River Plant problems.

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k<. y .s t i I ASSESSMENT OF SALT DESPOSITION IMPACIS AT CRYSTAL RET.R f r i i I t Envirorvnental Protection Agency { Office of Policy and Management [ Region IV t August 31, 1988

2.. Assessment of Salt Decesition Imosets v. at Crystal rii ve r PUFPOSE The Environmental Protection Agency (EPA) has prepared this report to cupport permit decisions for discharges to waters of the United States under the Clean Water Act and emissions to the air under the Clean Air Act. This report directly responds to the comments and the c-ncerns presented by Dixie M. Hollins and Louie N. Adcock (Hollins Cerporation) at the public hearing held on June 22, 1988 and subse-quent written comments on a proposed NPDES permit. These comments roised questions regarding the impacts of salt drif t from the pro-posed modi fications and additions to the cooling towers at Florida Power Corporation's (FPC) Crystal River Power Plant. Florida Power Corporation has requested that they be allowed to oper-ote their Units 4 and 5 cooling towers at higher drift rates than cur-rcntly permitted. FPC is also proposing to add cooling towers for Units 1, 2, and 3 to reduce current unacceptable thermal impacts from present operation. These actions would result in increased salt depo-cition on the area. This report evaluates the potential impact to the area's vegetation and water resources resulting f rom the several possible permitting scenarios. The scenarios are initial permit con-ditions, current emissions, FPC's requested changes in emissions for units 4 and 5, and the addition of proposed helpe' cooling towers for units 1, 2, and 3. Conclusions and recommendatier.s are presented fol-lowing this evaluation. BACKGROUND This section of the report gives a brief histvry of the Crystal River power plant ecmplex and cites some of the earlier reports addressing colt drift FPC's Crystal River power plant complex is locat ed on the Gul f o f Mex-ico in northwestern Citrus County, Florida outside of the town of Cryst al Ri ver, Florida. In January 1981 the EPA issued an Environmen-tol '. pact Statement (EIS) which examined and discussed the impacts of the construction and operation of two E95 megawatt capacity c oal-fir ed electric generating plants at the existing Crystal River Complex. Prior to the EIS, FPC issued a Site Certi fication Applica-tion (SCA) for Crystal River Units 4 and 5 in 1977. The SCA was a cupport document for FPC's application to construct the coal-fired power units. FPC has been operating Units 1, 2, and 3 since 1966, 1969, and 197/ r espectively. Units 4 and 5 have been operating s*nce 1982 and 1984 r e sp ec t i vel y. Mitigating measures were developed in the EIS to reduce adverse im-pccts from the construction and operation of Units 4 and 5. The EIS recommended conditions to the icsuance of FPC's NFDES permit. Specif-ic ccnditions addressing the impact of salt drift were included in the permit and are: 1), the maximum dri f t rate of the cooling towers of Units 4 and 5 shall be 0.0005% of

tha circulating cooling wotor, cnd 2), FPC choll cenduct cnd rcport roculto of c vcgototien cnd Ocit dcpociticn conitoring progrcm ccccpt-cble to the EPA and the Florida Department of Environmental Resources (FDER). The maximum allowable drift rate of 0.0005% was, at the time of the EIS, thought to be the lowest achievable drift rate using the best dri f t eliminator technology available. Since the initiation of operation of Unit 4 in October, 1982, FPC has cubmitted monthly vegetation impact reports and annual salt deposi-tion monitoring reports to the EPA.* Additionally, EPA has pre-pared a salt drift impact analysis (Crystal River Cooling Tower Salt Dri f t Evaluation, December 23, 1987). The December 1987 report was prepared to address four natural draft cooling towers to be used to reduce the thermal discharge of Units 1-3. The assessment included the salt deposition from Units 4 and 5 operating at a drift rate of 0.0023%. Also, FPC issued a salt drift analysis report in June 1988 to address the combined salt drif t of increasing the drif t of Unit 4 cnd 5 cooling towers and the additional drif t of the helper cooling towers for Units 1, 2, and 3.8 When unit 4 was placed in operation ond tested, it was found to be in compliance with the permitted dri f t rate. However, it was found to be cperating signi ficantly below its designed thermal ef ficiency. In an attempt to increase the cooling capability of the Unit 5 cooling tower, the spray system for the t ow-or was modi fied during construction. When the Unit 5 tower was start-od up and tested, it was found to have increased thermal ef ficiency (over Unit 4), but the measured drift rate exceeded the permitted dri f t rate limit. As directed by EPA, FPC instituted studies of how the dri f t rate could be reduced and conducted an evaluation of the im-pact of the increased salt dri f t. Based on the results of this evalu-otton and ongoing environmental studies, FPC has requested that EPA increase the permitted dri f t rates for Units 4 and 5 cooling towers. While FPC's request is being considered, EPA has issued an administra-tive order allowing FPC to operate Unit 5 cooling tower at the elevat-cd drift rate as long as there are no adverse impacts of the salt drift on the indigenous vegetation.

Crystal River Salt Drift Annual Feports, 1982-83, 1983-94, Applied Biology, Inc.

Crystal River Salt Drift Annual Feport, 1984-85, Florida Power Corporation Crystal River Salt Drift Deposition Monitoring Annual Reports 1985-86, 1986-87, KBN Engineering and Applied Sciences, Inc.

Submittal to EFA of revised deposition contours, June 1988, KEN /FPC W

e

t 3 1 gAj,J DRIFT ANALYSIS This section of the report describes the amount of salt dri f t and colt deposition occurring and expected to occur at the Crystal River i fccility. Salt dri f t modeling has been per formed and the salt deposi-tion rates have been predicted by the model. The deposition predict-cd by the model is compared to the current salt deposition monitoring dota. Units 1-3 are presently cooled using a once-through salt water sys-tcm, that is they do not use cooling towers. FPC proposes to con-ctruct helper (nonrecirculating) cooling towers to reduce the thermal impact of the liquid waste discharge of Units 1-3 to the Gulf of Mext-co (Crystal Bay). These cooling towers will be operated only as nec-COsary to assure that the plant discharge temperature does not exceed 97.0 #F as an instantaneous maximum nor 96.5 0F as a maximum three hour average. Therefore, the towers will not be operated i f plant discharge temperatures remain below 96.5 0F. Although periodic opera-tion of the towers could begin as early as late April during unusual warm weather conditions and extend until late October, near continu-ous operation of the towers will generally not occur except during the summer months (June through September). The cooling procons in a cooling tower is primarily due to evapora-tion. To achieve this evaporation, the water to be cooled must be brought into contact with large volumes of air. This contact of air cnd water results in the entrainment o.f small droplets (drift parti-cles) in the air from the top of the cooling tower to the atmo-cphere. Since the water used at the site is salt water from the Gulf, the dri f t droplets contain a high concentration of dissolved calts (primarily sodium chloride with smaller amounts of potassium cnd manganese salts). Drift particles from cooling towers do not stay entrained in the air indefinitely. The salt dri f t is carried by prevailing winds and falls (due to gravity) as salt deposition on the land around the cool-ing tower. The amount of salt deposited on any speci fic area is gen-orally dependent upon its distance from the cooling tower, it s loca-tion relativ? to the tower and to the prevailing winds, the height of the cooling teuer, the cooling water and ambient air temperatures, cnd environmental conditions such as topography and locations of sur-face waters. Using meteorological data, the size of the drift drop-lets, the height of the cooling tower, the temperature of the exit gases, and the salt emission rate, it is possible to calculate the calt deposition at various locations around the cooling tower. This type of calculation, called salt deposition modeling, is complex and is subject to errors based on the assumptions and periods used for data averaging. However, a model can be compared to field data and used to make decisions about projected salt dri f t and its impact to the environs surrounding the cooling tower.

\\ 4 N Areas that are close to large salt water bodies receive natural salt deposition from wind blewn salt water droplets. The EIS stated that the area received a natural background salt deposition f rom the Gul f of Mexico of 3.4 g/(m*-yr). Two years of pre-operational monitor-ing (1980 and 1981) indicated background salt deposition rates of 3.5 cnd 6.7 g/(m= yr).= Additionally, the FPC annual deposition moni-toring reports suggest that the data from the Open Control monitoring location (see Figure 1) could be used as an approximation to deter-mine background deposition." EPA's report, here in, will use high values of background deposition to give the analyses a conservative (i.e. worst case) bias. The measured pre-operational value of 6.7 g/(m= yr) is averaged with the Open Control measured deposition rate for the 1985/86 monitoring period. For use in this calculation, the modeled deposition at that location of 2.2 g/(m=-yr) was sub-tracted from the monitored value of 7.8 g/(m=-yr) to yield a calcu-lated 1985/86 background of 5.6 g/(m* yr). The average of these S values (5.6 and 6.7), 6.2 g/(m* yr), is used in this report as the total annual background salt deposition for the Crystal River site. In their June, 1988 report, KBN Engineering and Applied Sciences, Inc. (KEN) stated that 2.5 g/(m* yr) of the annual salt deposition is contained in rainfall. The annual background dry salt deposition used in this report is therefore 3.7 g/(m* yr). McVehil-Monnet Associates performed modeling analysas for the opera-tien of the cooling towers at Crystal River." This modeling shows only the predicted salt deposition from the cooling towers and does not include the annual background salt deposition. Figure 2 shows the expected annual salt deposition contours from Units 4 and 5 cool-ing towers operating at a dri f t rate of 0.0005% (i.e. the NPDES per-mit conditions)." Figure 3 shows the expected annual salt deposi-tion contours from Unit 4 and 5 cooling towers at the existing condi-tions of an average drift rate of 0.0014% (Unit 4 at 0.0005% and Unit 5 at 0.0023%) at an 81% capacity f actor with a concentration of dis-co1ved solids in the cooling water of 32,000 parts per million (ppm).* Table 1 lists the annual salt deposition rates at the mon-itoring loc atior.s as extr apol at ed from the modeled results (Figure 3) for Units 4 and 5 cooling towers at the existing dri f t rate and the i total annual salt deposition rates (i. e. predicted deposition from Units 4 and 5 plus background deposition). = Submittal to EF A of revised deposition contours, June 1988, KEN /FPC.

Crystal Piver Salt Drift Deposition Monitoring Annual Peports, 19C5-66, 193C-87, KEN Engineering and Applied Sciences, Inc.

"Cooling Tower Dri f t Deposition Crystal River Units 4 & 5 Florida Power Corporation (0.0005%), (0.000% Drift Pate), and (0.005% Drift Fate) Cooling Tower Drift Deposition Crystal River Units 1,0,0,4 & 5 Florida Power Corporation (0.0005% Dri f t Rate), and (0.002% Drift Pate), McVehil-Monnett Associates, March 1986

Ibid

' Submittal to EF A revising deposition contours and modi fied by mem:randum of Charles Vaplan, Water Menegement Division, EPA Fegion IV. June S, 1959.

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lk. U The open bucket method is used to collect the salt deposition at Crys-tal Rive *.* Measurements of the salt collected in the buckets are t made monthly and the data are reported as annual deposition rates. Ta-ble O displa"s the measured annual deposition rates as reported in [ the 1985/86.nd 86/07 annual Salt Dri f t Deposition Monitoring Re-l' peris. The annual monitoring periods are from October 1985 tnrough September 198o (for the 1985/86 annual report) and October 1986' 4 through September 1987 (for the 1986/87 annual report). Table 1 4 Predicted Annual salt Demonition [ (Values reported in g/(m* yr)) 2 h Units 4 and 5* Tota 18 Dry Total

f l

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Annual Measured Total Decesition l

1985/86 1986/87 l g/m* g/m* 1 1, c I 1 1 Open Test 7.9 7.5 [ NW Open Test 10.3 6.0 4 NE Open Test 13.4 6.7 L i SW Open Test 9.7 7.6 Open Control 7.8 4.1 l \\ j

Crystal River Salt Drift Annual Repert 1982-84, Applied Eiology, j

nc., May 7, 1986.

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1 b, 9 The measured annual salt deposition at the monitoring sites reported in the 86/87 annual report are all less than the total deposition pre-dicted by the model for those locations. For the 05/86 monitoring pe-riod all the monitoring sites, except the NE Open Test site, had mea-cured deposition rates which were higher than the model's predicted rotes. Tables 3 and 4 list the measured deposition rates for the two monitoring periods, the average predicted deposition rates, and the porcent difference between the modeled rates and the measured rates. Note that the model predicts the NW Open Test to receive 36% greater ooit deposition than the NE Open Test site would receive, but the NE Open Test site received higher salt deposition than the NW Open Test cite for both monitoring periods. Table 3 Medeled Demonition vs Measured Demesition (1995/RE) Measured Modeled Percent Difference Monitoring Deposition Deposition C(mod / meas) - 13 x 100*/ Location (g/m*-yr) (g/m'-yr) Open Test 7.9 10.3 56 i NW Open Test 10.3 10.1 17 l NE Open Test 13.4 8.9 -34 i SW Open Test 9.7 11.5 19 f Open Control 7.8 8.4 7 i Table 4 M: deled Deme 4t tien vs Measured Decoettien (199E/971 i i Measured Modeled Percent Difference l Monitoring Deposition Deposition C(mod / meas) - 13 x 100% Location (g/m* yr) (g/m*-yr) Open Test 7.5 12.3 64 I NW Open Test 6.0 10.1 100 NE Open Test 6.7 8.9 30 SW Open Test 7.6 11.5 51 Open Control 4.1 8.4 105 r

3 10 Figure 4 shows the expected annual salt deposition f rom Unit 4 and 5 cooling towers at a dri't rate of 0.00:3%.* Figure 5 shows the ex-pected annual salt deposition from Units 4 and 5 cooling towers (at a drift rate of 0.0003%) and the helper cooling towers for Units 1-3 Cat a drift rate of 0.002%).** In conducting its evaluation of potential salt dri f t impacts, EPA se-1ected a worst case scenario more critical than the one used by KEN in its June 1988 report. The EPA analysis assumed 1.' continuous op-cration of the existing and proposed cooling towers for Units 1-5 dur-ing the summer months (June through September) where KBN used an oper-1 cting factor of 81% for Units 4 and 5, 2) a salt dri f t quantity for Units 4 and 5 cocting towers based on a total dissolved solids (TDS) concentration (i.e. the amount of salt in the circulating water) of 38,000 parts per million (ppm) where KBN used 32,000 ppm, 3), a salt dri f t quantity for Units 1-3 based on TDS of 32,000 ppm where KBN used 09,100 ppm, and 4) a worst case natural salt deposition of 6.2 g/m* yr where KBN used 5.1 g/m"-yr. The TDS concentrations used by EPA are the highest measured historical values from the tower with the maximum concentrations during the month with the highest values t cince the Unit 4 cooling tower began operation. The TDS concentra-tion for Units 1-3 cooling towers is lower than the TDS for the Units 4 and 5 cooling towers because Units 1-3 towers use nonrecirculating cooling towers and will not concentrate solids in the circulating wa-ter as much as recirculating towers (Units 4 and 5 towers) do. Table 5 lists the daily salt deposition rates at worst case short duration r conditions as noted above. These daily deposition rates are used in the Vegetation Impact Analysis presented later in this report. Six scenarios are evaluated in this report reflecting six di f ferent l sets of operating conditions and associated salt dri f t. The first ocenario is the original permit conditions; Units 4 and 5 cooling tow-l ors cperating at a 0.0005%, and Units 1-3 using once through cool-ing. The second scenario is the existing conditions at Crystal Riv-l org Unit 4 cooling tower operating at 0.0005% drift rate, and Unit 5 operating at a drift rate of 0.0023%, and Units 1-3 using once through cooling. Scenario 3 is increasing the drift rate of Unit 4 [ ond leaving all other conditions the same. This scenario corresponds to FFC's request to change the permitted dri f t rate to 0.0003% for the cooling towers for both Units 4 and 5. Scenario 4 is the addi-l tion of the proposed helper cooling towers to the original permit con-l ditions: Units 1-3 cooling towers operating at a drift rate of 0.000% oach, and Units 4 and 5 cooling towers operating at a dri f t rate of 0.0005% each. Scenario 5 is the addition of the proposed helper cool-ing towers to the existing conditions: Unit 4 cooling tower drift rate being 0.0005%, Unit 5 cooling tower drift rate being 0.00:3%, cnd Units 1-3 cooling towers drift rates being 0.000% each. Scenario l 6 is increasing of Unit 4 dri f t rate and adding the proposed helper j cooling toweral Units 4 and 5 cooling towers dri f t rates being 0.0000% each, and Units 1-3 cooling towers dri f t ratas being 0.000% I osch. l { l '5sbmittal to EF A revising salt deposition contours, KEN /FFC, June 1SES. j I

- Ibid.

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y-i i >^- \\ i .a.I n. A i s. 'l N ~~ l AREA 1T y, /.5 - N/ ,/ 4, t x,.- f e r L e a / \\ ,l' I~ ~ g.. l-} \\ p 6 t I l ( ' m y ~.. l N(em ~ s,. x g ,,,, \\ -~ y n ( s T l 1, y = ~' w.,,,,,, /- -r .yk. ] F

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t gj.,;ty g-S ' /.) 1, I FIGURE 5 ) Proposed maximuni Deposition: Units 4 and 5 at Drift Rate of 0.0023% Helper Cooling Towers at 0.0021 'i

2., 13 Table 5 Crystal River Units 1-5 Cooling Towers Werat-Case Dai! v Deneg(((gn Pat es (g/m. day) e A. Depositten at northern property line en rigure 5 (Used for Area ! assessment) scenario Units 4 & 5 Units 1-3 Baelaround Iglal 1 0.009 0.0 0.010 0.019 2 0.C24 0.0 0.010 0.034 3 0.040 0.0 0.010 0.050 4 0.009 0.025 0.010 0.047 5 0.004 0.028 0.010 0.062 6 0.040 0.008 0.010 0.078

3. Deposition at the 5 g/m*-yr contour north of the plant on Figure 5 Scenario Unit 4 t, 5 Units 1-3 Esekaround 121A1 1

0.003 0.0 0.010 0.013 2 0.010 0.0 0.010 0.020 3 0.016 0.0 0.010 0.026 4 0.003 0.009 0.010 0.022 5 0.010 0.009 0.010 0.029 6

0.01G 0.009 0.010 0.035 C. Deposition at an average of A and B (used for Area !! Assessment)

Econario Unit 4 ?, 5 Units 1-3 Backaround Ig1&L 1 0.006 0.0 0.010 0.016 2 0.017 0.0 0.010 0.027 3 0.008 0.0 0.010 0.038 4 0.'006 0.019 0.010 0.035 5 0.017 0.019 0.010 0.046 6 0.000 0.019 0.010 0.057 D. Deposition at the 2 g/m*-yr contour north of Area !! Scenario Unit 4 05 Units 1-3 Packaround Iqtgl 1 0.001 0.0 0.010 0.011 2 0.004 0.0 0.010 0.014 3 0.006 0.0 0.010 0.016 4 0.001 0.004 0.010 0.015 5 0.004 0.004 0.010 0.018 6 0.006 0.004 0.010 0.000 m Description of Scenarios: 1: Permitted dri f t rate, both towers at 0.0005% Os Emisting conditions, Unit 4 tower at 0.0005% and Unit 5 tower at 0.00:3% 3: Fequested drift rate increase for Unit 4 tower to 0.00:3% 4: Scenario 1 with Units 1-3 helper towers at drift rate of 0.000% 5: Scenario 2 with Units 1-3 helper towers at drift rate of 0.000% 6: Scenario 3 with Units 1-3 helper towers at drift rate of 0.002%

\\ a VEGETATION IMPACT ANALYSIS 1 This section of the report describes the indigenous vegetation at Crystal River and provides an analysis of the impact of salt depost- ) tion (described in the previous r,ection) on the vegetation of two ar-oas north of the plant. These areas (shown on Figure 5 as Areas ! cnd !!) are selected because they are the land off of FPC property predicted to have the greatest impact from the salt deposition from } the cooling towers. i j Figure 6 shows the biotic communities that are found in Areas I and Table C lists the percentages of the types of vegetation J found in the biotic communities.** Using Table 6 and Figure 6, Area ! and !! can be described by area, types of vegetation, and the censitivity of the vegetation to salt. The vegetatien in area north l of Area !! is primarily planted pine, however due to the distance [ b from the FPC power facility, detailed figures and biotic information i is not available. j t Area ! is a 15-20 acre crescent shaped tract of Hollins Corp. land ad-l Jacent and just north of the FPC northern property boundary. Area ! vegetation is coastal hydric hammock which is a mixture of isolated hammock areas and wetland forests. The most abundant species found f in the hydric and coastal hydric communitics are very salt tolerant, defined as very tolerant, tolerant and high resistance species. The next.,most common species are the low resistance species, and the least. common species are moderate resistance species. Are's;1f'is a 050-300 acre tract of Hollino Corp. land contain&ng 110-130 acres of coastal hydric' hammock, 55-65 acres of salt marsh, 55-65 acres of planted pine, 05-35 acres of mixed vegetation and ever-green scrub, and approximately 5 acres of fresh water marshes. Salt marsh is made up of 100% of species that have a very high tolerance to salt. The planted pine community at Crystal River comprises most-ly plants that have a moderate resistance to salt. Plants with high resistance to salt damage are the next most common type of vegetation in the pine plantation, and low resistance species are the least com-The mixed vegetation and evergreen scrub communities are a mix mon. of the coastal hydric hammock, mesic hammock, and the planted pine communities and display vegetation sensitivity that is a combination of the three other biotic communities, mostly moderate and high resis-tance species with the remainder being low resistance species.

SEFA superimposed the contour lines from Figure 5 (herein) over Figure 0-1 from Environmental Assessment of Salt Dri f t Impacts of Florida Power Corporation Crystal River Units 1,2,3,4 & 5 with Natural Draf t Cooling Towers, MSN, August, 1985.

Figure 0-1 represents the biotic communities at Crystal River.

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s. Tablo & P69Wiellom Pertenlegoteof Venetation tamelma at Crvatal Rivne (Overstory/Understory)* Ramistames Levels Stotic i Ve y Tolerant, I i l Very Lowel Community ^ Very High, High l Moderate i Low l Intoleranti i Coastal and. l l l 1 I Coastal i l l l l Hydric I 52.4 % 1 73% i 10.3 % 1 0.0 % i H.m.oc k i i i i nesic.nd i i i i i Hydric 1 30.9 % 1 33.5 % 1 15.6 % 1 < 0.5 % 'l Ha mmoc k I i 1 1 1 l l = Pine Flat. I I l t i woods and i I I l l Pine Plant = 1 13.6 % 1 06.4 % 1 0.0 % 1 0.0 % i atton i. I. I. I. i Freshwater 8 l Marsh 8 The freshwater and saltwater earshes do not I I Saltwater I contain an overstory/understory vegetation level. I Narsh l l (thrubs and Herbaceous Species)** Eggi at anen Lavain plotte 1 Very Tolerant, I l l Very Lowel Co** unity i Very High, High 1 Moderate i Low I Intoleranti 1 .c r. Coastel and 1 l l l l Coastal l l l l l Hydric I 64.7 % i 11.8 % 1 23.5 % i < 0.5 % i Hammoak I I I i l l l Meetc and l l l l l Hydric I 52.5 % i 16.7 % l J0.4 % i < 0.5 % l Ha mmoc k I I l I i Pine rlat. 8 l l l l woods and 8 l l l 1 Pine Plant-l 38.3 % 1 46.5 % i 14.9 % l < 0.5 % l atten I I l i I i e Preshwater I l l l l Marsh l 37.0 % 1 31.5 % 1 31.5 % i < 0.5 % 1 ~~ i l l l Saltwater I i i I l Marsh I 100 % 1 0% 1 0% 1 0% l l t + Overstory/understory are two dif ferent layers in a plant community. Tall trees, such as cypress and esk, cceprise the over= story, and trees of medium height, such as dogwood and maple, comprise the understory.

- The shrubs' and herbaceows spettes are the low lying plants in the cosawntty. Grasses, twshes and other short vegetation make up f

this level of plant c ommuni t i e s. (

For overstory/wnderstory, percentages are of Total !*portance Valwe

{ Inden. !aportance value is a parameter weed in twentsfying i veget ation pepulet t en det al impor t ance value a the sum of the relative domstty, relative dominance, and relative f regwenty of a l species. i for shrwts and herbaceous spe:tes percentages are of Total Grownd Cover.

The biota in the Crystal River area is made up of a majority of colt tolerant species (see Table 6). The overstory/understory vegetation lovel contains more salt tolerant vegetation than the low-lying sje-cies. This could be expected since the natural salt drift of the re-gion (from the Gulf of Mexico) is carried on the prevailing winds and will tend to impact the overstory/understory vegetation more than the thrubs and herbaceous species. The less salt resistant species have doveloped more readily at the ground because the. upper levt1 of va;4-totion provides a shield from salt deposition for the ground cover vogetation. The two marsh communities do not contain an oversto-ry/understory. The saltwater marsh, due to its highly saline water cnd its proximity to the Gulf of Mexico, comprises 100% salt resis-tcnt species. The freshwater marsh communities contain approximatuly cne third each of high, moderate ind low resistance species. In accordance with their NPDES permit, FPC has maintained and conduct-cd vegetation and salt deposition monitoring programs sines approxi-mately 1979. Additionally, a vegetation survey was included in work done f or the Eite Certification Application (FFC, 1977). The vegeta-tion monitoring consists of monthly inspections of tagged individual plants at selected locations, quarterly serial infrared photography of the area in a one mile radius circle around the FPC site, and quar-torly biotic inspections of the monitoring locations. The locations uoed for the deposition monitoring are used for the vegetation meni-toring (see Figure 1). KEN Engineering and Applied Sciences, Inc. (MEN) was contracted by FPC to prepare quarterly and annual salt depo-cition monitoring reports for the 1985/86 and 1986/87 periods. The two annual reports conclude that, alth'ough few symptoms of salt accu-mula) ten damage were documented, there were no consistent patterns or oynptoms of salt accumulation damage to the vegetation in the Crystal River area. The reports also state that the indigenous vegetation was generally in good condition. The reports f rom tne previous years also documented that there was no salt damage discovered by the vege-totion monitoring. O e e

l 1 ( K3N includod in their Juno 1988 report a grouping of plent opocios by [ ] their relative resistance to salt accumulation damage. Tho groups rcnged from very intolerant to very tolerant. Data was provided for t J the ranges of salt accumulation which would be expected to cause threshold damage to the plants and damage to 50% of their leaves (50% i 4 l loaf damage). These accumulation levels were used to determine how i long salt deposition could be tolerated on the plants before thresh-1 l old and 50% leaf damage might occur. The levels expected to cause damage through accumulation have been determined through laboratory i I cnd highly controlled field experimentation. The threshold damage i level is when the vegetation starts to show signs of stress. The 50% l 1eaf damage level is when 50% of the vegetation's leaves are showing 1 cymptoms of stress. Salt accumulation damage is often evidenced by necrosis. Table 7 lists these plant. groups and the average salt accu-i 1 sulation levels needed to produce threshold damage and 50% leaf dam-l cge to the species in the groups. For brevity, the lists of the spe-l cies found in the groups have been replaced by a representative spe-I cies for each group. These representative species were chosen be-cause they are found in the biotic communities at Crystal River. i Table 7 ) Accumulation Levels Causing Damage I Te Various Ece les at Crystal River J I l Threnheid Damace 50'4 Leaf Damace (g/m') ( g i Very Tolerant >4 > 10 (Mersh Elder 1 7 [ High Pesistance t j (Live OsO) 5 Moderate Resistance .7 2.5 (Sl ash Pine *i i, Low Resistance .3 .8 l (Ped Meele) I I l Very Intolerant 0.04 .2 j (Fleverine Deeweed)- Slash Fine is the predominant species found at the Crystal t 1 River Planted Fine area. Virginia Pine is listed as moderately resistant to salt accumulation damage and Pitch Pine is listed as highly resistant to salt accumulation damage. Slash Pine was chosen to be moderately resistant to give the analysis a [ conservative blac. f l 4 1 t

Tcblo 8 Time Between Rainf all Events Days Between Number of Number of Occurrences r3fnfa11 rvente* O?euvre9een Eeuel te er Leacee 0 171 368 1 55 197 2 39 44: 3 25 103 4 16 78 5 17 6 E 9 45 7 9 36 8 4 27 9 2 23 to 4 21 11 3 17 12 2 14 13 1 12 14 2 11 15 0 9 16 0 9 17 1 9 18 1 8 19 3 7 20 0 4 21 0 4 00 0 4 03 0 0 24 0 0 05 0 0 06 0 2 07 1 2 0 1 08 29 0 1 30 0 1 31 1 1

Rainfall events 0.11 inches /hr or greater.

This data as provided by KEN is for the four summer mcnths (June, July, August, September) for the following ten years 1974, 75, 78, 79, 81, 80, 83, 84, 85, and 1986. D + esse

%*b Tho KEN rCport of Juno 1988 diccuccoo how reinfo11 ovonto of 0.11 inch /hr or greater will wash accumulated salt residue from tho locvoo of the plants and presents an analysis of determining how often it must rain to prevent various salt deposition rates to reach accumula-tion levels that cause threshold damage and 50% leaf damage. Table 8 ( lists the number of occurrences for ten years, during the summer conths, that the time between rainfall events was equal to and/or longer than i day through 31 days.** The deposition rates (modeled and measured) for the operating condia tions of the 1985/86 and 86/87 monitoring periods are used in the Came analysis that KEN used in the June 1988 report. The results of the calculations are listed in Table 9 along with the salt deposition rates (from Tables 3 and 4 and corrected for salt deposition from rainfall) displayed as daily deposition rates. Also included in Ta-ble 9 are the number of occurrences during the summer months of 1986 (i.e. during the 05/86 monitoring period) when the time between rain-fall events was equal to or longer than the calculated times ("dry pe-riods") necessary for salt deposition to accumulate to the levels which might cause threshold and 50% leaf damage to vegetative species with low and moderate resistance to salt accumulation. The data for the summer months of 1987 (i.e. during the 86/87 monitoring period) have not been made available. r From the impact analysis, vegetaticn damage from salt accumulation greater than throshold damage to low resistance species should not have occurred in the 1985/86 monitoring period. This corresponds to the results of the vegetation monitoring. Since threshold damage is very di f ficult to recogni:e in field studies, it is understandable that no consistent patterns of salt accumulation damage to the indige-nous vegetation have been found at Crystal River. And, although the modeled deposition rates were different than the measured deposition rates, the rates predicted by the model would not have caused damage greater than threshold damage to low resistance species. The daily deposition rates listed in Parts A and C of Table 5 are used in an analysis identical to the one used by KEN. Table 10 lists fcr each cperation scenario, the number of days between rainfall ovents needed to cause threshold damage an6 50% leaf damage to spe-cies in Area ! that have low and moderate resistance to salt accumula-tion. Table 11 lists the same information for the species in Area The two tables also list the number of times that "dry periods" oqual to or longer than that required for the two levels of feract have occurred in the ten years of rainfall data in Table 8. Species l more resistant to salt accumulation damage than moderately resistant cpecies are not listed because the shortest time between rainf all i ovents to cause threshold damage to high resistance species is 39 days, a very low probability event during the summer m nths in Flort-da, and an event that did not occur during the ten years of record used for the analysis.

- Eurface Cbservaticns at Tampa, FL Naticnal Weather Service Station

(#10E40). m

Tho depoottien rotoo lictod in Tcbloc to end 11 includo o naturol dot-g/m -yr i :C5 o ty dry 661% depesttlen of 0.010 g/m*-day (C.: .dcys/yr). 'The deposition rates used for the Area !! analysis are tak-cn frona Part C of Table 5. The deposition rates presentec in Part C ore averages of Parts A and B. The salt deposition represented by the contour lines in Figure 5 change gradually from one contour line to the next. Area !! is large enough that the average of the two con-tour lines (from Figure 5) is more representative of the deposition rote than either the higher or the lower figure. Area I, on the oth-cr hand, i s not very large and is close enough to the contour line that using the deposition rate of that contour line is appropriate. 9 e e j

~~ \\ Tcb10 9 Vegetation Impact AnalyOls Fer the 35'Et and RE/97,ysmiterina Perieds Damage Causing Salt Accumulation "Levels (g/me) Lew eenistames Emmelen 3 M derate eenistames Emerien Monitoring. Locations &l Threshold Tnreshold 150% leaf Manages 150% leaf damagel Batt I (0.33 1 (0.8) 5 (0.7) 1 (2.5) I Deposition l i Occur B Days i Occur i Days lOccurl Rates (Days' lOccur* I Days. (g/m*-der) i I I I 5 I i 1 1 c=em Tant i I I I e i I I i modeled l I I I E I 1 l l (0.027) I 11 1 3 1 30 1 0 5

S I 0 1 13 1

0 i Meas. 05/86 I I I l g i i i I (0.015) I 20 1 0 1 54 1 0 5 47 1 0 I 169 1 0 l Meas. SC/87 I I I I B I 1 l t l 182 1 I 3 51 1 1 EB 1 (0.014) I 22 1 i l NW Eeem Testi l I l 5 l I I l Modeled i l I i 5 1 1 1 1 (0.0:C) I 11 1 3 1 30 1 0 5 27 1 0 I 15 l 0 l Meas. 85/66 l l I 1 5 1 1 l l (0.021) I 14 8 3 3 37 1 0 3 3J l 0 1 117 1 0 i Meas. et/07 I I I I E I I l l t 261 1 l E 73 1 I to 1 (0.010) i 30 1 l 5 l l EI,cesa Testi i i l 5 1 I I I medeled I l I l 3 I I I I (0.010) i 17 1 : I 46 1 0 5 40 1 0 1 143 1 0 i Meas. 85/06 I I I I E I I I I (0.030) I 10 1 4 1 27 1 0 3 23 1 0 I 84 1 0 l Meas. E6/87 I t i 1 g i I l l l 1 217 l 5 61 1 I 70 1 (0.010) l 24 8 -- = ! 5 l l l su cesa Testi i l I e i I I l Nodeled i I I I E I I I (0.0:5) I 1: I 3 I 3: i 0 5 28 4 0 1 101 1 0 i Meas. 85/86 I I I i e i l i I (0.0:0) i 15 1 : I 41 1 0 5 35 1 0 1 127 1 0 i Mesa. 86/87 l l l l 5 l I I I 8 179 I l t 57 1 3 50 1 (0.014) I 21 1 ~ l 5 C=e9 Ceatrell i I I E I I I i Mcdeled i 1, I l 5 I I l l (0.01&) l 19 1 1 I 47 1 0 3 43 1 0 1 155 1 0 i Meas. 85/86 I I I l 5 I i 1 1 (0.015) I 21 1 0 I 35 1 0 5 48 i 0 1 172 l 0 i Mess. et/87 I I I I E I I I I 1 1 570 1 (0.004) I, CS I. t. 182 l. 3 160 1 i g 6 The measured deposition rates listed in Tables 3 and 4 are reduc ed by 2.5 g/m**yr, the ammuel salt deposition contributed as reinf all, then divided by &S days /yr. l

Days Indicates the nueter of days without rainfall for salt depcottton to accumulate to the indicated levels which might cawse damage.
Cccurt Indicates the nu*ber of occurrences whom doetge eay have occur red in the sweser months of the ment tor t mg perled. For esam-ple, at the measwred deposttton rate at the dW Caen Test ette, threshold damage cou.d have occurred two times becawse there were two cry periods t%at lasted 15 days or Icmger in the summer m<nths in 1986.

The 85/86 data is used with the depositicn rates predicted by the model. Indicates that the rainfall cate has not been made available. j l

,~s 'M Tcb10 10 i Area ! Vecetation Immaet Anaivsis t Lew Resistahem See:tes MSderate Fenistance Smeetes i Damage-Causing Accumulation Levels (g/m*) l Threshold l 50% Leaf E Threshold I 50% Leaf I salt I (0.3) I (0.8) B (0.7) I (2.5) I Deposition Rate lDays* 10ccur*I Days 10ccur E Days i Occurt Days 10ccur I (g/m*-day) i I I I E I I l ,1 t scenarie 1-1 I I l 5 I I I I i 16 I 9 I 42 1 0 E 27 1 0 1 132 1 0 1 0.019 I I I I E I I l I seenarie 2 I I I I E I I I I I 9 1 03 I 24 1 2 E 21 1 4 L 74 1 0 l 0.034 l 1 I l 5 I I I I scenarie 3 l 1 I l 5 I I I i l 6 1 45 I 16 I 9 E 14 1 11 I 50 l 0 l 0.050 l l I I E I I I l seenarie 4 I I I I E I I l l I E I 45 t 17 l 9 5 15 I 9 I 53 1 0 l l 0.047 1 1 I I E I I l I H eeenerie 5 I I I I E I I I i 1 5 l 62 1 13 1 1 E 11 1 17 I 40 1 0 1 0.0E2 I I I I E I I I I l Seenerie 6 1 1 I l E I I I I l 4 1 78 I to l 21 5 9 l 23 1 30 1 0 l l 0.078 l l I 1 E I. I l I =

1. Days indicates hou many days are needed between rainfall events i

to reach the indicated accumulation levels that might cause damage. [

2. Occurs indicates the number of occurrences in the ten years of f

record that the calculated titr.e betueen rainf all events oc-curred. For example, at the deposition rate of Scenario 4 (0.047 g/m*-day) it would require six days without rain-fall l for the salt accumulation to reach the level that would cause threshold damage to low resistance species. There have been forty-five occurrences of dry periods six days or longer in the ten years of record. f I Scenarios and ceposition rates as presented in Table 5. } e l f l l i \\ l ~ .. 1

Tcblo 11 ArOO !! Venetation Immaet Analvain Lew Penistance Enecias Moderate Penistanee Esmeies Damage-Causing Accumulation Levels (g/m') i Threshold 150% Leaf Dam.E Threshold 850% Leaf Dam.1 Salt I (0.3) I (0.8) E (0.7) I (2.5) l l Deposition l E l Rate (Days

10ccur*I Days i Occurg Days laccur I Days l Oc r.cr l

/ (g/m*-day) l I I I E I I I I scenarie 1-l l l l 5 l I l l L 1 19 1 7 I 50 1 0 5 44 1 0 1156 10 l 0.01E I. I. I I E. I. I I. I. f s e e n a r i e,,,,2 i i i i E I I I I i 11 1 17 I 20 1 1 5 25 1 I 33 10 I i 0.007 l 1 I I E I I I I i l l l l E l l scenarie 3 I I I I E I I I I r l 8 1 27 I 21 1 4 E 18 I 8 I EE Io I 0.038 I I I I E I I I I l l l l E l l l l seens*ie 4 l l I I E I .I I I L 1 9 1 23 I 23 I E 20 1 4 I 71 10 1 0.03: 1 I I I E I I I I l l l l E l l l l Scenerie 5 l l I I E I I I I r 7 I 36 I 17 I 9 5 15 I 9 I 54 iO I 0.046 I I I I E I I I I l l l l l E l scenarie E I I I l 5 I I I I I I 5 l E I 14 1 11 E 10 1 14 I 44 10 t 0.057 I I. I. I E I I I l i _g i I

1. Days: indicates hou many days are needed between rainf all events to l

reach the indicated accumulation levels that might cause damage. l

2. Occur s indicates the number of occurrences in the ten years of record that the calculated time between rainfall events oc:urred.

l' For example, at the deposition rate of Scenario 4 (0.03 g/m*-day) it would require nine days without rainfall for the salt accumulation to reach the level that would cause threshold damage to low resis-tance species. There have been twenty-three occurrences of dry peri-l ods nine days or longer in the ten years of record. .1cenarios and deposition rates as presented in Table 5. + t I t M

g .gg The data from Tables 10 and 11 are used to assess the impacts to Ar-cas I and II vegetation. Each Scenario is presented and described, cnd the impacts are presented as how frequently the two different types of damage (threshold and 50% leaf damage) may occur. The terms used to describe pctential damage frequency include four ranges of the number of occurrences during the ten years of record that the time between rainfall events was long enough to cause damage, rarelv means that there were 1 to 4 occurrences occasionallv: means that there were 5 to 14 occurrences recularivt means that there were 15 to 24 occurrences often: means that there were 25 or greater occurrences The salt deposition rates are predicted for wo*st case conditions. The impact period is during the summer months with elevated operating f actors and higher salt concentrations in the circulating water. The measured deposition rates were less than the modeled rates in nine out of ten casas (Tables 3 and 4), implying the model presents worst case. Most of the biotic communities being impacted have upper vege-tation levels that contain majorities of salt televant species which provide shielding for the more salt sensitive species in the ground-cover vegetation level. For these reasons, the actual damage is ex-pected to be less than predicted by this worst case analysis. 4 Area I Evelvation l The data for this impact evaluation is presented in Table 10. Area I is 15 to 20 acres of Hollins Corporation land at the northern proper-ty boundary of the FPC Crystal River Complex. Coastal hydric and hy-dric hammock are the vegetative communities found in Area I. The ovei story /understory vegetation of these communities are predominant-ly ecmposed of salt tolerant species. The majority of thr low ver's-tance species found in the hydric and coastal hydric comm..aities are found in the low lying v'egetation level. The impacts to the majority of the low resistance species will be less due to the shielding s#- fact of the upper level vegetation, Scenario 1, original permit conditions, Units 4 and 5 cooling tower drift rates = 0.000$% and no helper towers: The analysis predicts oc-casional (7 occurrences in ten years of data) threshold damage to low resistance species. Scenario 2, existing conditions, Unit 4 cooling tower dri f t rate = 0.0005%, Unit 5 cooling tower dri f t rate = 0.0023% and no helper tow-crs: The analysis predicts regular (23 occurrences in ten years of data) threshold damage and rare (2 occurrences in ten years of data) 50% leaf damage to low resistance species. Rare (4 occurrences in ten years of data) threshold damage to moderate resistance species is predicted. -m

't Sconcrio 3, incrocsing tho dri f 3 veto of Unit 4 cooling towar, Unito 4 and 5 cooling tower drift rate. = 0.0003% and no helper towers: The analysis predicts threshold camage to low resistance species of-ten (45 occurrences in ten years data). Occasional (9 occurrences in ten years of data) 50% leaf damage is predicted for low resistance cpecies. Occasional (11 occurrences in ten years of data) threshold damage to moderate resistance species is also predicted. Scenario 4, adding the helper cooling towers to the original permit conditions, Units 4 and 5 cooling tower dri f t rates = 0.0005% and Units 1-3 cooling tower drift rates = 0.0023%: The analysis predicts threshold damage to low resistance species of ten (45 occurrences in ten >aars of data). Occasional (9 occurrences in ten years of data) 50% leaf damage is predicted for low resistance species. Oc c asi on s1 (9 occurrences in ten years of data) threshold damage to moderate re-oistance species is also predicted. Scenario 5, adding the helper cooling towers to the existing condi-tions, Units 4 cooling tower drift rate = 0.0005%, Unit 5 cooling tow-or dri f t rate = 0.0003%, Units 1-3 cooling tower dri f t rates = 0.000%: The analysis predicts often (62 occurrences in ten years of data) occurrences of threshold damage and occasional (10 occurrences ten ye'ars of data) occurrences of 50% leaf damage to low resistance cpecies. Regular (17 occurrences in ten years of data) threshold dam-age to moderate resistance species is predicted. Scenario 6, increasing the dri f t rate of Unit 4 and adding the helper towers, Units 4 and 5 cooling tower drift rates = 0.0003% and Units 1-3 cooling tower drift rates = 0.000%: The analysis predicts often (7E occurrences in ten years of data) occurrences of threshold damage and re;ular (17 occurrences in ten years of data) occurrences of 50% leaf damage to low resistance species. Regular (23 occurrences in ten years of data) threshold damage to moderate resistance species is predicted. Arts II Evaluation Table 11 lists the data used in this avaluation. Area II is 260 to 300 acres of Hollins Corporation land north'of Area I. The impacts to the biotic communitier, with ovetatory/understory vegetation levels will be less than the impacts described below. However, the ten acrev of freshwater marshes feu-d in Area II do not have an uppar veg-etation level. The impact of the vrait dri f t on the low resistance species will not be y educad by shleiding from t(;11er plants. This im-pact may cause a species shi f t in the mcesheL. Over time salt tolur-ant species may bec:.me more abundant and there may be fewer low resis-tance plants. Scenario 1, original permit conditions, Units 4 and 5 cooling tower dri f t rates = 0.0005% and no helper towers: The analysis predicts oc-casional (seven occurrences in ten years of data) threshold damage to low resistance species. No other damage from operating at permitted drift rates is predicted. m O

i VI

e Secnario 2, existing conditions, Units 4 and 5 cooling tower dri f t rotes = 0.0005% and 0.00 3%, respectiv91y, and no helper towers: The cnolysis predicts regular (seventeen cecurrences in ten years of da-tc) threshold damage and rare (one in ten years of data) 50% leaf dam-cGo to low resistance species.

Rare (two occurrences in ten years of dota) threshold damage to moderate resistance species is predicted. Sconario 3, increasing dri f t rate of Unit 4 cooling tower, Units 4 cnd 5 cooli ng tower dri f t rates = 0.00:3% and no helper towers: The enalysis predicts threshold damage to occur of ten (27 occurrences in ten yearn of data) and 50% leaf damage to occur rarely (4 occurrences in ten years of data) to low resistance species. Occasional (8 occur-rcnces in ten years of data) threshold damage to moderate resistance cpecies is predicted. Scenario 4, adding the helper towers to the original permit condi-tions, Units 4 and 5 cooling tower drif t rates = 0.0005% and Units 1-3 cooling tower dri f t rates = 0.002%: The analysis predicts regular (03 occurrences in ten years of data) threshold and rare (two occur-ronces in ten years of data) 50% leaf damage to low resistance spe-cies. Rar e (4 occurrences in ten years of data) threshold damage to moderate resistance species is predicted. Scenario 5, adding the helper cooling towers to the existing condi-tions, Units 4 and 5 cooling tower drift rates = 0.0005% and 0.0003%, rospectively, and Units 1-3 cooling tower dri f t rates = 0.000%: The enalysis predicts threshold damage to, occur of ten (31 occurrence 4 in ton years of data) and 50% leaf damage to occur.occssionally (9 occur-ronces in ten years of data) to low resistance species. Occasional (9 occurrences in ten years of data) threshold damage to moderate re-sistance spe:ies is predicted. Scenario G, increasing the dri f t rate of Unit 4 cnd adding the helpar cooling towers, Units 4 and 5 cooling tower dri f t rates = 0.0003% and Units 1-3 cooling tower drift r ates n 0.000%: The analysis predicts threshold tjamage to occur often (60 occurrences in ten years of dr.ta) and 50% leat damage to occur occasionally (11 occurrences in ten yeart, of data) to low resistance species. Occasional (14 occurrences in ten ynars of-data) threshold da nage to moderate resistance species is predicted. Qt_ hor A_r e e s ( Salt deposition north of Area 11 can be assumed to be the sama as the doposition described in Part B of Table 5 for areas close to the 5 O m*-yr contour line and approach the deposition described in Part /D of Table 5 for areas closer to the 2 g/m* yr contour line. The 2 g/m" yr contour line is not completely drawn on the figures that ac-company this re t, Salt deposition from the cooling towers will de-crease with dist .c e f rom the cooling towere until it reaches a negli-gible level. The area between the 5 and 2 g/m=-yr contour lines ~ cnd north of the FPC property boundary is estimated to be between 1,000 and 0,000 acres. Planted pine is the predominant biotic commu-nity. Salt marsh and coastal hydric and hydric hammock comprise the rest of the area between the 0 and 5 g/m* yr contour linoc. m

5 In tho nema mathed usod for Aroes I end II, the doposition roton from Part B of Table 5 is used to evaluate the impacts to the vegetation outside of and closely adjacent to Area II. Likewise the deposition rates from Part D of T ',ble 5 will be used to evaluate impacts to ar-cas cloue to the 2 g/m* yr contour line. Scenario 1 of Part B, permitted conditions, Units 4 and 5 cooling tow-cr drift rates = 0.0005% and no helper towers: The analysis predicts rare (2 occurrences in ten years of data) occurrences of threshold damage to low resistance species. Thers is no other damage predicted for this scenario. Scenario 2 of Part B, existing conditions, Unit 4 cooling tower dri f t rate = 0.0005%, Unit 5 cooling tower dri f t rate = 0.0023% and no help-or towers: The analysis predicts occasional (9 occurrences in ten years of data) threshold damage to low resistance species. There is no other damage predicted for this scenario. Scenario 3 of Part B, increasing the drif t rate of Unit 4, Units 4 and 5 cooling tower drift rates = 0.0023% and no helper towers: The analysis predicts occasier.a1 (14 occurrences in ten years of data) threshold damage and rare (1 occurrence in ten years of data) occur-rences of 50% leaf damage to low resistance speciec. The analysis predicts rare (2 occurrencLs in ten years of data) occurrences of threshold damage to moderate resistance species. Scenario.4 of Part B, adding the helper towers to original permit con-ditions;"; Units 4 and 5 cooling towers drift rates = 0.0005%, Units 1-3 cool (ng. towers dri f t rates = 0.002%: The analysis predicts occa-wienal (11. oecurrences in ten years of data) threshold damage to low resistance species. There is no other damage predicted for this sce-navio. Scenario 5 of Part B, adding helper towers to existing conditions, Unit 4 cooling tower dri f t rate = 0.0005%, Unit 5 ccoling tower dri f t rato = 0.0023%, Units 1-3 cooling tower drift rates = 9.002%r The aralysis predicts regular (21 c:ctrrences in ten yeare. c. ' dataf thrazhoin damage and rare (1 occurronces in ten years of Ostt) 50% Iwaf damage to low resistance species. Tau analysis predicts rare (2 occur rences in -ten ye ars of data) of threshold damage to moderate re-sistance species. Gcenario E cf Part B, adding helper tower s and increasing dri f t rate of Unit 4, Units 4 and 3 cooling tocht dri f t rates = 0.00 0%, Units 1-3 cooling tover dri f t rates = 0.002%: the analysis r.redicts regular (23 occurrences in ten years of data) threshold damage and rare (2 oc-7 currences in ten yuars of data) 50% leaf damage to low resistance spe-cies. The analysis predicts rare (4 ociurrences in ten years of da-ta) threshold damage to moderate resistance species. i b O I

C# gi the Ug/m yr centour lina. The e The damage described cbovo 10 calt deposition and the potential for damage is reduced as the dis-i tance from the cooling towers is increased. The dr.aage described be-low, is gi the 2 g/m*-yr contour. Scenario 1 of Part D, permitted conditions, Units 4 and 5 cooling tow-ors dri f t rates = 0.0005% and no helper towers: The analysis predicts rare (2 occurrences in ten years of data) threshold damage to low re-cistance species. There is no other damage predicted for this scenar-io. Scenario 2 of Part D, existing conditions, Unit 4 drift rate = t 0.0005%, Unit 5 drift rate = 0.0003% and no helper towers: The analy-ois predicts rare (4 occurrences in ten years of data) threshold dam-age to low resistance species. There is no other damage predicted i for this scenario. i Scenario 3 of Part D, increasing Unit 4 cooling tower dri f t rate, Units 4 and 5 cooling tower dri f t rates = 0.00:3% and no helper tow-ors: The analysis p r edicts occasional (7 occurrences in ten years of data) threshold dariage to low resistance species. There is no other damage predicted for this scenario. Scenario 4 of Part D, adding helper towers to permitted conditions, Units 4 and 5 cooling towers dri f t rates = 0.0005% and Units 1-2 cool-ing towers drii' rates = 0.000%: The analysis predicts rare (4 occur-rences in ten years of data) threshold damage to low resistance spe-cies. There is no other damage predicted for this scenario. Scenario 5 of Part 0, adding helper towers to existing conditions, Unit 4 cooling t ower s dri f t rate = 0.0005%, Unit 5 cooling tower l dri f t rate = 0.0022% and Units 1-3 cooling towers dri f t rates = 0.000%: The analysis predicts occasional (9 occurrences in ten years of data) threshold damage to low resistance species. There is no oth-or damage predicted for this scenario. Scenarto 6 of Part D, adding helper towers and increaving Unit 4 cool-ing t aver dri f t r ate, Unitr 4 and 5 cooling towerf d r !. f t rates = 0.0002% and Units 1-2 cooling to.'urs drift rateu a c 400%: The analy-Els predict s occasional (9 occ.urrences in ten years of data) thresh-old damage to low resistance species. There ir,r.o other damage pre-t dieted for this scenario. SOIL IPf_A_ CTS ANALyfg The EIS and the SCA desericed tha soils and 91c1'sgy of the Crystal River area (see Figure '7).'" Studies using irrigation water of vari-ous salt concentrations have shown that sensitive crope (e.g. corn, tomatoes) displayed no adverse reactions to irrigation with water hav-ing salt concentrations up to 500 parts per million (ppm).5"

- Environmental Impact Statement Florida Power Corporation Crystal River Units 4 and 5, EPA Region IV, EAP, NCPA Compliance Se: tion, July 1920
*Cuality Criteria for Water, EPA, July 1994.

0 G N

f* 3 F ~ HYOpfC g PtNE g FRESH g SLASH PINE g ug MEsiC g COAST AL HYDRIC SALT MAR $M gCCASTAL Skif M.aRSH g I I IL MARSH g I FLATWOO55 bAE 5 Crud MAMMOCE MAMMOCK I I HAMMOCK IMAuudK I g e .I.. <. , g A. WET SEASON , p. A \\ ijf } 3, . @f, {j, ] _ j ;*- -,!j x w g f g W W .s's; y <;w g I -y g, M,j'b I 1 +t* g

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b l g ( B j 's 3. f .(,;. -., , g t d B. DRif SEASON i i au 1 A 9y 1 u .I.. ~~ a... . q((agggf.g,*-.. i.- ' '. ':_ "nW,er'- r; 1 i i 2 p .3 f,[,,__..!,,{, I [J, J,7T , { ',,_ )),, _ } WATER VEGETATION $3BSTR ATt' (follS) s. O R PRECIPITATION CAasAGE PALg Ditt* ticeaucg k EVAPOTRANSP1 RATION SOUTHERN jy\\ j PINES .n RE D-CED AR 3 I i i SANDS SCRUB w; LIVE OAK go (EVERODEEN) OROUMO W ATER FtOW '*D 5 OAK 5 -19vp4ri:f]I? = - SALT W ATER MARSH SAW [ L QRASSES eme4 PALMETTO ,m T I_ J k 7 r 7 ~ FLORIDA POWER CORPORATION IFiguro CONCEPTUAI.lZED F1. ANTIS 0ll.i?ATER RELATIONSHIPS OF THE PROPOSED P1.Ah! SITE PnOPOSED CRYSTAL HIVER UNITS 4 & 5 ( CITRUS COUNTY, FLORIDA ( SOURCE: ENVIRONtAENT11. SCIENCE AND ENGINEERGIG,INC.,1977 \\\\ FIGURE 7 I

I

1 i

1 1 Similar studies have shown that soils in arid and semiarid climates display no adverse conditions or build up of inorganic constituents l from irrigation with water having salt concentrations up to 480 ppm.** Hamid climates, like those cimilar to the Crystal River ar-on, have mitigating effects on salt accumulation impac ts on soil. To address the concerns of salt accumulation in soil, a salt solution ccn be simulated by assuming to dissolve the annual salt deposition into the annual net rainfall. Then, this simulated salt solution can bo applied to tha soil. A worst case scenario would be to maximi:e the salt deposition and minimi:e the net rainfall. The average annu-ol rainfall in the Crystal River arca is 50 inches per year.17 The ovapotranspiration rate for that part of Florida ranges from 44 to 42 inches per year.5" The worst case scenario would require 19.2 g/m= yr of salt (E.2 g/m*-yr background salt deposition plus 13.0 g/m2-yr maximum proposed salt deposition due to salt drift at FPC northern property boundary) dissolved into a not rainf all of two inch-os per year to yield a "solution" of 347 ppm salt in water. This val-ue is below the concentrations needed to cause adverse impacts on coils in arid and semiarid regions. SUFFACE WATEP IMPACTS The geology at Crystal River is one of sandy soil intermixed with limestone formations (see Figure 7). In some places the limestone is very near the surface and can create pockets of sandy soil that are caparated from the main body of soil.. This separation also includes the groundwater that is entrained in the soil. The groundwater in the area is hydraulically af fected by the Gulf of Mexico and in areas close to the shore the groundwater can become brackish. However, the pockets separated by the limestone will hold freshwater and support freshwater hammock vegetation species. The hydraulic characteristics of the freshwater pockets, as shown in Figure 7, are not isolated but are interactive with the main body of ground water and the seasonal changes in precipitation. During dry periods the water in the freshwater hammocks tends to drain through the limestone due to the-lowering of the groundwater table. The f r eshwat er marshes become dry. During wet periods, the hammocks will fill with water from the groundwater table and the marshes tend to over flow. To considr~ a worst case scenario, the freshwater pockets can be as-oumed to be antirely isolated and the salt water solution from the COIL IMPACTS ANALYSIS can be "poured" into the freshwater pockets. This mexf. mum solution of 347 ppm should have no adverse af fects to the water or the vegetation in the freshwater pockets.

- Lond Truatment of Municipal Wastewater, Army Corps of Engineers, 1977.

Water Atlas of United States, Garaghty, Miller et al, 437G. '"Ibid. -m

w. \\ It to oxpcetod that tho frochwator pockoto do not concontrato calt. They intcroct with tho groundwator (i.o. they cro not entirely isolat-cd), there is a net positive rainfall in the area, and the salt water impacting them is not very concentrated in salt. However, because the freshwater pockets are very complex systems, it is recommended that baseline data be cellscted and a monitoring program be installed to determine the impacts that may occur to the freshwater pockets. CONCLUSIONS AND PECOMMENDATIONS The current salt deposition at Crystal River has not been shown to be causing damage to the indigenous vegetation. Either of the two pro-posed changes to the operating conditions (i.e. increasing the drift rate of Unit 4 cooling tower and the addition of helper cooling tow-crs for Units 1-3) will increase the total salt deposition to levels that may occasionally cause serious (i. e. 50*/. leaf damage) damage to plant species with low resistance to salt in Areas I and II. The com-bined effect of the two proposed changes results in a salt deposition rate that may regularly cause threshold damage to moderate resistance i cpecies on a small portion of Hollins Corporation land (Area I). It i is expected that there will be no observable damage to the vegetation north of Area II. The analysis is presented on a worst-case basis. The measured salt deposition has been less than amounts predicted by the model. It is likely that the salt deposition will be less than the amount used in the analysis. Additionally, the natural division of the plant spe-cies in the biotic communities (overstory, understory, and groundcov-or) will reduce the amount of salt impacting the species with low tol-l orance to salt accumulation dr. mags. The freshwater marshes, comprising only five acres, do not have the advantage of the shielding ef f ect of upper vegetation levels. This relatively small amount of wetlands should not be destroyed by the salt deposition impacts, but a species shift may accur causing the more salt tolerant plant species to rdowly comprize more of the [ freshwater mar shes. l There should be no adverse impacts to soils frcm the talt deposition [ i of any of the proposed changes or the combination of the two. The l amount of salt being deposited is below levels shown to be safe to 4 soils. The same can be said regarding the concent ation of salt in the non-saline sur f ace waters. The sur f ace waters of cor.cern, the freshwater pockets, have interaction with the groundaatcr, and in the event that they become i solated, the salt being deposithd in the freshwater is not suf ficient to cause salt concentrations in the wa-ter which would be expected to cause damage to the vegetation growing i in the freshwater pockets. t [ t i i e c - - -. - -,.. - -,.,.-_

y It. summation, implementing either or both of the proposed operational changes at Crystal River has been predicted to result in adverse im-pacts to the environs of the area. These impacts are expected to be localized and affect only the most sensitive species. Also, this cnalysis is believed to overestimate the amount of damage. EPA believes that the benefit derived from the improvement of the aquatic habitat and the improved e f ficiency of the cooling towers sub-stentially outweighs the potential adverse impacts to the local ar-ca's terrestrial vegetasion. Over 800 acres of aquatic habitat will be improved.to meet water quality standards. This area's astuarine waters are important resources which must be protected under the re-quirements of the Clean Water Act and Florida Water Quality Stan-dards. The uncertain loss or damage to low resistance species on 300 ccres or less, although of concern, is not considered sufficient to ellow continuance of violations of water quality standards or the con-tinuance of low ef ficiency use of the cooling tower for Unit 4. Due to the un:ertainty surrounding this analysis and to assure that si gni fic ant impacts do not 6ccur, the following conditions should be pla-:ed on the EPA, PED permit modifications for Units 4 i d 5:

A.

Florida Pcwer Corporation shall continue the existing vegetaticn impc:t and salt deposition mcnitoring prcgram. Florida Poser Cor- }

sration shall submit to EPA P.egion IV and FD2R, by no later than October 31, 1998, a plan to expand and modify the existing moni-t: rin; pregram.

This expanded monitoring program must be ap-proved by FDER and EPA and shall include the following: 1. An increase '.n the number of depccition monitors and m:nthly ve; station m:nitoring locations to include a representative number of freshwater marshes and coastal hammock and coastal hydric hammock communities. O. Initiation of a soil salt sampling program which includes ob-taining bcselinn soil salt concantration tata by sampling stil at representative Ic:stions. 3. Iritiation of a surface water salt sampling program which in-cludes obtaining baseline surface water salt e.onc ent r at ion data by sampling water in a representative number of fresh-water m ar shes. 1 4 Inclurion of deposition, Wil, f r esh vator, and vegetation moni t or i n c; stations on appropriate portiens o' Hollins Corp. land. 5. Collection of data to more accurately determine the natural background deposition at Crystal River. D. In the event that significant damage to terrestrial plants occuru, FPC shall immediately rsport su:h findings to CPA and the FCCP. Within 90 days theratf ter, FPC shall submit to EPA and FDER an assessnent of the damage, cptions to reduce the im- , pact, and a prop: sed ceurse of action to correct the da.. age. U;on the diroction of tha EPA or F0ER, FPC shall implement cor-re:tive acticn. O w*

e, 10 %,,$ 'pO ) UNITro STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV ,g 343 COURTLAND STREET ATLANTA GEORGI A 30345 SEP 1 1988 MALIC toTICE to. 88FLO36D DATE: IMICE OF NPDES PERMIT DETERMINATIONS Company: Florida Power Corporation Incation: St. Petersburg, FL NPDES Pemit No. FL0000159 Permit Issuance Date: SEP 1 1988 Permit Effective Date: OCT 1 1988 After due consideration o[ the facts applicable to the aeove-named facility and the requirements and policies expressed in the Clean trater Act and appropriate regulation, the Regional Administrator has determined that the National Pollutant Discharge Elimination System permit should be issued in accordance with the tentative determinations previously announced. The permit will be effective on the date given above provided that no request for an adjudicatory hearing and/or legal decision is granted by the Agency. If such a request is granted, all contested provisions of the permit will be stayed pending final Agency action. All uncontested provisions of the permit will become effective on the effective date given above. REX 7 JEST FOR AIDUDICATORY HEARING AND/OR LEGAL DECISION Any interested person my submit a requent for an adjudicatory hearing and/or legal decision within ten (10) davs of the receipt of thia no: ice. The ro pest and tho copies thereof must bo submitted to the Regi.cnal Hearing Clerk, Enviromental Protection Agency, 145 Courtland Street, t;.E., Atlanta, Georgia 30355. Iha aub.aission of the request will be within the time period if mailed by Certified Mail before the tv.th day. The request must: (i) State the reme ar.d address of the person mking such requests (ii) Identify the interest of the requestor which is offected by the croposed issuvce, denial or modification of the pemit contained in the retermination of the Regional Administrators (iii) Identify any persons whom the request represents; (iv) Include an agreement by the requestor to be subject to examination and cross-examination and to mke any employee or consultant of such requestor or other person represented by the requestor available for examination and cro:s-eumination at the expense of such requestor or such other person upon the request of the Presiding Officer, on his o.tn motion, or on the motion of any party. 1 2

\\ 6 ' (v) State with particularity the reasons for the request; (vi) State with particularity the issues proposed to be considerad at the hearings and (vii) Include proposed terms and conditions which, in the judgment of the requestor, would be required to carry out the intendment of the Act. Additional information on adjudicatory hearings and legal decisions is found at Title 40 Code of Federal Regulations, Section 125.36, 39, Federal Register 27081. 1 l i 4

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September 1, 1988

RESPONSE

TO WRIITEN CCMME! TIS CRYSTAL RIVER PCHER PIA!C UNITS 1, 2, AND 3 NPDES NO. FIh000159 1. Dixie M. Hollins and Louie N. Adcock, Hollins Corporation, 6/30/88. A. p 1. Description of Hollins Corporation holding was provided. Pesponse Ccoments noted. B. p 2. Ccients submitted on February 17, 1987, were reaffirmed insofar as they apply to the revised alternative thermal controls. Responses Ccment noted. C. p 2, 3, and 4. Opined that EPA response to previous coments did not adequately address the rehabitation of submerged lands. Disagreed with EPA conclusions as to the area affected by the discharge and to whether the impact was due to heat. Questioned whether the thermally igacted area can be restored even if the thermal discharge is reduced; since they opine that much of the damage results from silt deposition from the Cross Florida Barge Canal and Crystal River Plant dikes and spoil islands. Responses Construction activities on the Cross Florida Barge Canal (CFDC) ceased j in the general period of 1964. Abcut this time, Florida Power Corporation was constructing the intake and discharge canals for their Crystal River Units 1 and 2. EPA agrees that Phese construction activities undcubtedly induced scme level of added turbidity and silt deposition in Crystal Bay. Similarly, erosion of the newly created spoil islands bordering the CFBC and the plant discharge dike added to the initial turbidity and deposition load. EPA believes that this initial turbidity and silt load has diminished over time. For example, shallcw shoreline of scrae spoil islands asscciated with the barge canal has since been colonized by coergent narsh plants which will tediato shore erosion effects of wave action. The early effects of the probable turbidity and deposition on aquatic life, particularly the attached mero41gao and saagrasses, remin unkncwn. Evidence coll 9cted since 1974, howver, indicates that 3,urbidity and silt deposition 1 effects origidating frcm c.hese run-rmde structures are not responsible for the majcv loss of attached plent cerrmnities in the discharge area of Crystal Bay. l CryJtal River Units 1, 2, and 3 becar:e operational in 1966, 1969, and 1977, res;cctively. With the proposud conatruction of Unit 3, the Crystal Bay area ? becco the focus of intensive physical, chunical and biological studies. Persuits of these studies (1974) clearly dcmonstrated the presence and distribution of bottcm attached meroalgae and scagrasses in Crystal Bay which included the f.itake and discharge areas. With Unit 3 placed into cperation in 1977, and durirg the folicwing years of cperation 1978-1983, approximately 800 acres of previcusly vegetated bottcm habitat in the discharge became devoid of seagrasses and meroalgae (Crystal River 316 Dronstration Study, 1983-1984). With the cperation of Units 1, 2, and 3, water tc@eratures of 91.4*F (33*C) to 96.8'F (36'C) were ecmon cccurrence in the discharge area, particularly in the 800 acre zone of bay tottom previously reported (1974) ac supportirn attached plants. These observed tmperatures far exceed the thermi tolerance of meroalgae and the cptimum terporature rarne of scograsses.

hEI2 TEM CCMMENTS Turbidity values in the discharge zone associated with the cperation of Units 1, 2, and 3 averaged between 5 and 6 Nephelcmetric 'Ibrbidity Units (Nit) during the 1983-84 316 demonstration study. During this sane period, turbidity in the non-therm 1 area of Crystal Bay south of the seven-mile dike averaged between 4 and 5 N'IV. The apparent slight increase in turbidity in the discharge zone could easily be related to resuspension effects frcn the area which was devoid of attached plants. Under scm storm conditions when winds are directly onshore, resuspension effects in the discharge area (which is. devoid of plants) beccrne nere apparent as shown in the 316 danonstration. One of the runerous ecological benefits of an attached plant ccrmnity is stabilization of the substrate. Se difference in the turbidity regime of the discharge area and the non-thermal area of Crystal Bay was not significant. We non-therm 1 area supports an abundance of attached macroalgae and seagrasses. Frcm the pericd of 1974-1984, the sediment ccanposition of the bay bottcn both within the discharge and non-thermal areas was studied. W e prcportions of silt, clay, and sand fraction of the sediments for either area remained the same and unchanged during the study period. Hence, dispecportionate silt deposition in the discharge area is not apparent when considering the silt or clay ccuponent of the sedimnts associated with the non-thermal area south of the seven-mile dike. ne non-thermi area presently supports an abundance of attached mercalgae and seagrasses. Based upon the above discussions and results of the 316 dmonstration study, there is no evidence that turbidity or siltation are factors responsible for the masured loss of approximately 800 acres of attached macroalgae and sesgrasses in the discharge area. Excessive discharge tecperatures are considered by EPA to be responsible for the reasured loss of this important rarine habitat and associated animals. l The installation of the prcposed helper cooling tcwors will result in a discharge tmperature regi un similar to thermi conditions prior to the cperation of Unit 3. Since the substrate, i.e. sediment quality, of the area appears unchanged frce the of non-therral areas Supporting seagrasses and macroalgae, EPA expects recolonizatico by attached plants will occur. We Florida Power Corporation will be required to supplement recolonir.ation should the natural prccess to ineffective. D. p 2. Opined that the EPA response to previws ccrmnts did not adequately suigh concerns for the accumvistion of salt drif t residue in arcunts which ray ultinately cause chloride contamination and impace to indigentm flors m.d fauna. Disagreed with EPA conclusions that the salt drif t will not impact plants adjacent to the site on t.uth FPC and Hollins ).and. l of salt depcsition Fesponse: EPA has conducted an indep<.ndent asses e nt inpacts and concluded that there should to no adverse inpacts to the indigenous f auna of the area and no long term sh;nificant impacts to the vegetation. As indicated belcw, scm short duration inpacts may occur. EPA evaluated vegetation types reported as ranging fecm very tolerant to intolerant ard divided into two plant ccam1 unity types overstery/understory (e.g. live oaks, pine trees) and shrubs and herbaceous s;ccles /Ag. holly bush, mrsh grass). We EPA analysis i U.S. Envircanental Protectien "Agency, Of fice of Policy and Managment, Pegion !V, Assesment of Salt Cuposition Irpacts at Crystal River, August 31, 1988.

WRITIEM CCtNCES 3 - :) - utilized a worst case scenerio which was more critical than that used by FPC2 and assessed potential inpacts using short-tem drif t deposition rates (one to 10-day periods) as if they were occurrirg continuously over the entire four-month sumer period of helper tower cporation. The mjority or the species that make up the overstory/understory in the Crystal River site area are high and moderate resistant plants with the majority of the 2 icw resistance species located in the groundcover layer of the plant ccumunity. ne Crystal River area contains a negligible amcunt of salt intolerant vegeta-tion 2. Figure 1 shows the location and the types of the biotic ccr= unities located near the Crystal River that are potentially subject to salt drift inpact. he rotontial danage to vegetation has been divided into two types of damage; thresho.d damge and 50% leaf damage. Threshold damage is when the plant being impactei begins to shcw signs of stress. 2 reshold damage caused by salt deposi-tion is dMficult to identify in field studies because there are usually other scurces t stress impacting the vegetation. ne 50% leaf darage level of stress caused L y salt deposition is evidenced by 50% of the leaves of the plants being daraged. Necrosis is a ccranon a sign of salt darage. he current vegetation monitoring program has ret fcund any consistent synptces of salt damage to the plants at Crystal River. Area I (See Figure 1) is a 15-20 acre portion of land that will receive the greatest salt deposition not on FPC prcperty. The vegetation in Area I is coastal and ccastal hydric haarock. The upper levels of vegetation in Area I are restly high resistance species, These taller plants will receive the rajority of the salt deposition and will shield the low-lying vegetation frco the salt deposition. The icw resistance species are rest cctmen in the grcundcover level of vegetation. He salt deposition ha-the potential of causing 50% leaf darage to low resistance species; hcuever, the shielding effect of the tall vegetation will reduce the amount of salt deposited on the icw resistance species and the asscciated darage to those species. There may to threshold drage to moderate resistance species in Area I. Hcwever, this potential darage should not be observable. The largest area of impact, Area II, is 250-300 acres that is cc@ rised of plam ccrmunities that have an overstory/understory, except for the freshwater carshes. The overstory/understory epacies, beiro taller than the grcundcover vegetatico, will receive a rajority of the salt depositicn, thus shielding the low-lying species. The salt deposition bas the potential of causing 50% leaf damgo to icw resistance species. Hcwever, tne shielding effect of the taller vegetation will redu o any potential irpacts frca salt de;csition. There my be occasicnal threshold damage to mcdorato resistance s;ocies, although this damage shculd be unotocrvable. There are abcut five acres of freshwater earshes in Area II that do not contain a cancpy and will receive the full salt deposition. The species in the freshwater r.urshes are abcut one third each of Icu, rederate, and high resistance species. De salt deposition may cause damage to the icw resistance species which might result in a shif t of the plant pcpulation tcward a higher percentage of core salt tolerant species. There should te no observable impacts north of Area II. 4 KM Engineering and Applied Sciences,~Inc., Envircrrmtal Asssessnent of Salt Drift Irpacts frcn Florida Power Corporation Crystal River Plant, June 1988.

WPREEN CCNMEhTS E. p 2. Opined that there have been inadequate data accumlated to detemine definitely whether or not accumulation of salt drift will kill plant species in the hamock areas and fresh water marshes or contaminate those areas or substantially change the chemical balance and make them uninhabitable to indigenous flora and fauna. Response See Response D. We acnthly vegetation monitoring data has shown no evidence of damage due to salt drift. he resistance levels of the various species in the Crystal River area used for predicting inpacts to the vegetation have been determined through laboratory experiments and frm data obtained via field observations. We model used to estimate the salt deposition rates is considered to be state-of-the-art and generally predicted higher salt deposition rates than were measured at the site, thus offering a further factor of safety. A study using irrigation water of varicus salt concentrations showed that sensi-tive crops (e.g. corn) displayed no adverse reaction to irrigation water with 3 salt concentrations up to 500 pp. In arid and semiarid climates, soils have shown no adverse conditions or build-up of inorganic constituents from irrigation 4 water with salt concentrations up to 480 pp. ne concentration of salt that could exist fecm the maximum projected drif t rate at the northern FPC prcperty line digsolved in the minimum net rainfall has been calculated to be less than 350 ppn3 Although the hamocks are sonewhat isolated frcm the predcminant hydrcgeologic conditions, the isolation is not total (solution channels exist or overflow occurs during high rainfall periods). However, even if the hamnocks or marshes wre totally isolated, a concentration of 350, ppm of salt should have no impact on the water or plants. Berefore, ro damage.is expected to soil, ground-water, or plants due to uptake of this water. F. p 2. Interpreted the KBN Reports to indicate that a significant impact will occur on a portion of the Hollins property for periods of rainfall separated by 10 days or more and further that there will be damage to the plant life in the area but that there would be scme opportunity for "a } recovery" of the damigo during years with greater than normal reinfall. i Does not want mgo that needs to be recovered frcm. Response: See Posponse D. ha time betwen rainfall events is not the only j important variable in determining impacts to vegetation cn Hollins pecperty. ne natural shielding that the canopy vegetatien g',ves to the low-lying species is of great importance. We cancpy vegetation is made up of mostly salt tolerant species. Reso tall plants should not be damaged by the salt deposition. G. p 2. Cpined that the permit dcas not restriet the months of cperation of l the towers and that such limitations should to included in the permit to j minimize drif t. depositlon. Response: Inclusion of such a condition in the pomit is not considered necessary since the economics of the system will dictate minimum use consistent with meeting j permitted tmperature limitations. Operation of the helper cooling tcwer systcm will raise operating costs and will result in lost power (for pumps and motors) which cculd otherwise bo sold. t 3 U.S. Environnontal Protection Agency, Quality Criteria for Water, July 1976. 4 U.S. Amy Corps of Engiscors, Land Treatment of Municipal dastewster,1977 l 5 U.S. Enviromental Protection Agency, of fice of Policy and Management, Fogion IV, Assessnent of Salt Deposition Imparts at Crystal River, August 31, 1988.

WRI2 TEN CCM1ENIS H. p 3. Reiterated previous conments on impacts and drage caused by construc-tion of the Cross Florida Barge Canal when experts had previously indicated that there would be none. Responses Ccmnents noted. I. p 4. Opined that the towers should not be installed due to the potential for salt drif t daruge to currently viable lands; i.e., accept the damage to a relatively small area of submerged land rather than expending tremerdous sum in experimention, which may result in damage to many acres of upland, while not ensuring the rehabilitation of the presendy impacted area. Response: Over 800 acres of aquatic habitat will be igroved to meet Florida l Water Quality Standards requirements by the proposed action. Potential, though not expected to be observable, igaets to land offsite frcm FPC property would be limited to an area of not more than 300 acres. ne Clean Water Act (CWA) requires ccmpliance with Florida Water Cuality Standards, and EPA cannot issue a l pemit which will not meet those standards unless a variance is granted under Section 316(a) of the CWA, which is applicable to themal discharges only. Wat section provides that any alternative limitations on the thermal cogonent of the discharge must assure the protection and propagation of a balanced, indigenous population of shellfish, fish and wildlife in and on the body of water into which the discharge is made. It folicws that EPA cannot issue a permit which does not address the danage caused by the discharge. See, Decision of the General Counsel No. 58, In R) Bethlehem Steel Corporation, March 29, 1977 (the k W nistrator must independently interpret and apply state water quality standards' % ensure ccgli-ance with Section 301(b)(1)'(c) of the CWA). EPA has tentative"f Jotermined that the alternative thermal limitations associated with helper cc v11ng tcwers are consistent with Gection 316(a) and Florida Water Cuality Standeuls requirments. Also see previous responses. i J. p 3. Indicated concern that portions of the Hollins property are underlain i with near surface limo rock formations and other areas where deeper lim rock i layers produce basins (isolated wetland areas of both marsh and hardwood l l harock) in which surface waters are not flushed by surface rainfall to the Gulf and in which salt will accmulate and result in icng term damage. Res;cnse t Se(s Response E. i K. p 3 and 5. Indicated that the FN prcycsal cbes not provido for estab-lishmont of a trenitoring progra.: for salt drift deposition to document baseline soil conditions or measure deposition, vegetation, or accumulation l I in the soils. Response Althcugh rn impacts to soil and freshwater are expected, EPA plans to 4 6 modify the existing NPDES and FSD permits for Units 4 and 5 in the near futuro, FPC will be required to increase the nutter of deposition and vegetation monitor-i I irn stations included in the approved monitoring program to include a ropresenta-tive number of hanmock areas and freshwater mrshes. We monitoring program 1 will also be codified to include initiation of soil arx! freshwater sampling to establish baseline salt concentrations, r:nasure future concentrations, and evaluate changes which could inact vegetation prior to the ir pacts beccmirn 0 U.S. Envirorrental Protection Agency, Of fice of Policy and Manaccrnent, Fagion IV, Assesment of Salt Ecposition Igaets at Crystal River, August 31, 1988. i I

hRTITEN CCMtEWS - visibly evident. Additionally permit conditions will require FPC to continue its avaluation of inpacts and to implement corrective actions if significant damage occurs. Such action could include the installation of more efficient drift elim-inators. K. p 3. Indicated that the KBN Reports indicate impact to FPC owned land will occur and increased corrosion and associated maintenance costs will will be cause by the helper tcwers. Response: 'Ihe greatest impact on FPC land due to salt drif t will occur on areas previously impacted by the construction and cperation of the power plant or on existing salt marsh, which will not be further impacted. Scme impact to cemitive vegetation may occur in limited areas. Tower locations will be wiecceu to minimize to an acceptable level the inpacts of salt drif t on plant equipment. 2. Patsy Y. Baynard, Florida Power Corporation, 6/30/88. A. pp 1-2. Reduction of Heat. (1) FPC continues to believe that discharges have not caused substantial danage. (2) FPC supports the helper cooling tower alternate if themal reduction is required. (3) Cost information previously submitted was stnmarized. Responses: (1) EPA continues to disagree with the FPC position. (2) and (3) 2 Ccmmnts noted. t B. p 2. Seagrass Planting. FPC axpressed doubt that the area will support seagrass even af ter therinal reductions; hcwever, they do not oppose the permit requirements for monitoring seagrass recovery and replanting, if necessary, to the extent of the agreed $1.35 million (1988 dollars) and requests that permit include the raximum dollar amount. Response: EPA believes that both natural and replanted seagrass grcwth will be successful in a significant portion of the thermally impacted area, but agrees that regrcuth in the nearshore area of maximum continued therinal impact will probably not occur. Limits to expenditures have been approved in previcus correa-pondence and do not require inclusion in the permit. 4 C. pp 2-3. Entrairment/Inpingment. FPC continues to disagree with the EPA tentative Sectico 316(b) fiMings and deteminations; but agrees that there are no cost-effective technologies to modify the intake structures. FPC dces not object to the flow reduction or fish hatchery provisions of the draft permit. Responses Ccrmunts noted. D. pp 3-4. Specific Ccments. (1) p 3. FPC prepoacd that the limitation on total residual oxidants (chlor-ine) be changed to 0.08 mg/l based on selection of the naked goby (juvenile) Gobiosema bosel as the apprcpriate sensitive species rather than the Atlantic and tidewater silversides, tentatively selected in the Fact Sheet. f?C has requested a mixing zone for this paranoter frco the FDER and has requested that the approved mixing zone requirements be included in the pemit.

WRITIEN CCMiE2 TIS Response: EPA maintains that use of toxicity data for the silversides rather than the naked goby is appropriate to assure empliance with toxicity requirements of the Florida Water Quality Standards and has retained an effluent limitation of 0.05 mg/l in the permit. Consistent with the State 401 Certification, EPA has included the approved mixing zone designations in the pemit. (2) p 3. Errors in proposed limitation and reporting requirements for temper-ature rise in the draft permit were noted. 1 Responses Corrections have been made. (3) p 3-4. FPC requested that the phrase "time of total residual oxidant release" be used instead of "time of chlorine addition" for once-through I cooling water. Additionally ETC requested thnt each unit and each of the helper cooling tcwer discharges be allowed a 120 minute / day period for release of TIO and the effluent limit be 0.08 mg/1. Response: ne phrase "time of total residual oxident release" has been in:luded in the pemit and monitoring requirements have beva changed accordingly. Effluent Guidelines in 40 CFR Part 423 limit the discharge of TRO frcm a generating unit to 120 minutes per day. Wis period has been divided between the once-through ( l cooling water discharges to the discharge canal and the helper cooling tower discharges to the discharge canal. As noted in Item 2.D(1), the effluent limit l has been retained at 0.05 mg/1. (4) p 4. ETC has requested that discharge of TIO be allowed frcm OSN 006. Response ne requested change has been made to the pemit along with inclusion of monitoring requirements. Intake pumps for OSN 006 are located in close prox-imity to the once-through ecoling water intake pumps serving Unit 3 and may l contain a slight carryover of TRC frca chlorination of the ecoling water. -}}

3F0988-08, Forwards NPDES Permit FL0000159,effective 881001,per Tech Specs App B,Part II, Environ Protection Plan & Related Info

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3F0988-08, Forwards NPDES Permit FL0000159,effective 881001,per Tech Specs App B,Part II, Environ Protection Plan & Related Info

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