L-2010-059, Florida Dept of Environmental Protection - Wastewater Application Form 2CS - Permit to Discharge Process Wastewater from New or Existing Industrial Wastewater Facilities to Surface Water

Florida Dept of Environmental Protection - Wastewater Application Form 2CS - Permit to Discharge Process Wastewater from New or Existing Industrial Wastewater Facilities to Surface Water

ML100830442
Person / Time
Site:	Saint Lucie
Issue date:	03/18/2010
From:	Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation
References
EPP 3.2.4, L-2010-059
Download: ML100830442 (38)

Text

WASTEWATER APPLICATION FORM 2CS PERMIT TO DISCHARGE PROCESS WASTEWATER FROM NEW OR EXISTING INDUSTRIAL WASTEWATER FACILITIES TO SURFACE WATER INSTRUCTIONS

-FORM 2CS This form must be completed by all applicants who check "yes" to Item 11-C in DEP Form 62-620.910(1).

Public Availability of Submitted Information.

You may not claim as confidential any information required by this form or DEP Form 62-620.910(1), whether the information is reported on the forms or in an attachment.

This information will be made available to the public upon request. Any information you submit to the Department which goes beyond that required by this form or DEP Form 62-620.910(1) you may claim as confidential, but claims for information which is effluent data will be denied. If you do not assert a claim of confidentiality at the time of submitting the information, the Department may make the information public without further notice to you. Claims of confidentiality must be in accordance with Rule 62-620.302, Florida Administrative Code.Completeness Your application will not be considered complete unless you answer every question*

on this form (DEP Form 62-620.910(5))and on Form I (DEP Form 62-620.910(1)).

If an item does not apply to you, enter "NA" (for "not applicable")

to show that you considered the question.

Also, you may need a Plan of Study (POS) to develop Water Quality Effluent Limitations (WQBEL) required by Rule 62-650, F.A.C. Please contact the Department for information.

Follow-up Requirements (for New or Substantially Modified Facilities)

Although you are now required to submit estimated data on this form, please note that no later than six months after you begin discharging from the proposed or substantially modified facility, you must complete and submit items VII and VIII of this Form 2CS (DEP Form 62-620.910(5)).

However, you need not complete those portions of Item V requiring test which you have already performed under the discharge monitoring requirements of your permit.Definitions All significant terms used in these instructions and in the form are defined in the glossary found in the General Instructions which accompany Form 1.DEP ID Number If you are applying for a renewal of an existing permit or for a substantial revision to an existing permit, fill in your DEP Identification Number at the top of each page of Form 2CS. You may copy this number directly from Item I of Form 1. If you are applying for a permit for a proposed facility, leave the DEP Identification Number blank. The Department will assign a number.Item I You may use the map you provided for Item XI of Form I to determine the latitude and longitude of each of your discharge locations.

Item I Describe the design of each outfall, including construction materials used or to be used.DEP Fo.n 62-620.910(5) 2CS-2 Effedive Novemb 29, 1994 Item III Describe the surface water body which will be or is receiving effluent from the wastewater facility.Item IV A. The line drawing should show generally the route taken by water in your facility from intake to discharge.

Show all operations contributing wastewater, including process and production areas, sanitary flows, cooling water, and stormwater runoff. You may group similar operations into a single unit, labeled to correspond to the more detailed listing in Item III B.The water balance should show average flows. Show all significant losses of water to products, atmosphere, and discharge.

You should use actual measurements whenever available; otherwise, use your best estimate.B. List all sources of wastewater to each discharge point. Operations may be described in general terms (for example,"dye-making reactor" or "distillation tower"). You may estimate the flow contributed by each source if no data are available.

For stormwater discharges you may estimate the average flow, but you must indicate the rainfall event upon which the estimate is based and the method of estimation.

For each treatment unit, indicate its size, flow rate, and retention time, and describe the ultimate disposal of any solid or liquid wastes not discharged.

Treatment units should be listed in order and you should select the proper code from Table 2CS-1 to fill in column 3-b for each treatment unit. Insert "XX" into column 3-b if no code corresponds to a treatment unit you list.C. A discharge is intermittent unless it occurs without interruption during the operating hours of the facility, except for infrequent shut-downs for maintenance, process changes, or other similar activities.

A discharge is seasonal if it occurs only during certain parts of the year. Fill in every applicable column in this item for each source of intermittent or seasonal discharges.

Base your answers on actual data whenever available; otherwise, provide your best estimate.

Report the highest daily value for flow rate and total volume in the "Max. Daily" columns (columns 4-a and 4-b). Report the average of all daily values measured during days when the discharge occurred within the last year in the "Long Term Avg." columns (columns 4-a and 4-b).Item V"Production" in this question refers to those goods which the proposed, substantially modified, or existing facility will produce or is producing, not to "wastewater" production.

This information is only necessary where production-based new source performance standards (NSPS) or effluent guidelines apply to your facility.

Your estimated production figures should be based on a realistic projection of actual daily production level (not design capacity) for each of the first three operating years of the facility.

This estimate must be a long-term-average estimate (e.g., average production on an annual basis). If production will vary depending on long-term shifts in operating schedule or capacity, you may report alternate production estimates and the basis for the alternate estimates.

A. All NSPS and effluent guidelines promulgated by EPA appear in the Federal Register and are published annually in 40 CFR Subchapter N. A guideline applies to you if you have any operations contributing process wastewater in any subcategory covered by a BPT, BCT, or BAT guideline.

If you are unsure whether you are covered by a promulgated NSPS or effluent guideline, check with your DEP district office (Figure 1 in the Form I instructions).

You must check"yes" if an applicable NSPS or effluent guideline has been promulgated, even if the guideline limitations are being contested in court. If you believe that a promulgated NSPS or effluent guideline has been remanded for reconsideration by a court and does not apply to your operations, you may check "no." B. An NSPS or effluent guideline is expressed in terms of production (or other measure of operation) if the limitation is expressed as mass of pollutant per operational parameter:

for example, "pounds of BOD per cubic foot of logs from which bark is removed," or "pounds of TSS per megawatt hour of electrical energy consumed by smelting furnace." An example of a guideline not expressed in terms of a measure of operation is one which limits the concentration of pollutants.

DEP Form 62-620,91(X5) 2CS-3 Effedive November 29, 1994 C. This item must be completed only if you checked "yes" to Item V-B. The production information requested here is necessary to apply effluent guidelines to your facility and you cannot claim it as confidential.

However, you do not have to indicate how the reported information was calculated.

Report quantities in the units of measurement used in the applicable NSPS or effluent guideline.

The production figures provided must be based on actual daily production and not on design capacity or on predictions of future operations.

To obtain alternate limits under Rule 62-620.620(2)(b)3., F.A.C., you must define your maximum production capability and demonstrate to the Department that your actual production is substantially below maximum production capability and that there is a reasonable potential for an increase above actual production during the duration of the permit.Item VI A. If you check "yes" to this question, complete all parts of the chart, or attach a copy of any previous submission you have made to the Department containing the same information.

B. You are not required to submit a description of future pollution control projects if you do not wish to or if none is planned.Item VI1 (A, B, C, and D, including Tables VII-A, VJ1-B, and V11-C)This item requires you to collect and report data on the pollutants discharged from each of your discharge points. Each part of this item addresses a different set of pollutants and must be completed in accordance with the specific instructions for that part. The following general instructions apply to the entire item.General Instructions Part A requires you to report at least one analysis for each pollutant listed. Parts B and C require you to report analytical data in two ways. For some pollutants, you may be required to mark "X" in the "Testing Required" column (column 2-a, Part C), and test (sample and analyze) and report the levels of the pollutants in your discharge whether or not you expect them to be present in your discharge.

For all other, you must mark "X" in either the "Believe Present" column or the"Believe Absent" column (columns 2-a or 2-b, Part B, and Columns 2-b or 2-c, Part C) based on your best estimate, and test for those which you believe to be present. (See specific instructions on the form and below for Parts A through D.)Base your determination that a pollutant is present in or absent from your discharge on your knowledge of your raw materials, maintenance chemicals, intermediate and final products and by-products, and any previous analyses known to you of your effluent or similar effluent. (For example, if you manufacture pesticides, you should expect those pesticides to be present in contaminated stormwater runoff.) If you would expect a pollutant to be present solely as a result of its presence in your intake water, you must mark "Believe Present" but you are not required to analyze for that pollutant.

Instead, mark an "X' in the "Intake" column.A. Reporting All levels must be reported as concentration and as total mass. You may report some or all of the required data by attaching separate sheets of paper instead of filling out pages VI-I- to VII-10 if the separate sheets contain all the required information in a format which is consistent with pages VII-I to VJ11-10 in spacing and in identification of pollutants and columns. (For example, the data systems used in your GC/MS analysis may be able to print data in the proper format.) Use the following abbreviations in the columns headed "Units" (column 3, Part A, and Column 4, Parts B and C).DEP Form 62-620.910(5) 2CS4 Effedio, November 29. 1994 Concentration All reporting of values for metals must be in terms of "total recoverable metal," ppm -parts per million unless (1) an applicable, promulgated effluent limitation or standard specifies the rag/ -milligrams per liter ppb -pans per billion limitation for the metal in dissolved, valent, or total form; or (2) all approved p~g/1 -micrograms per liter analytical methods for the metal inherently measure only its dissolved form (e.g., hexavalent chromium).

If you measure only one daily value, complete only "Max.Mass Daily Values" columns and insert "I" into the "Number of Analyses" column lbs -(pounds (columns 2-a and 2-d, Par( A, and column 3-a, 3-d, Parts B and C). The mg -milligrams Department may require you to conduct additional analyses to further characterize g -grams your discharges.

For composite sample, the daily value is the total mass or average kg -kilograms concentration found in a composite sample taken over the operating hours of the T -tonnes (metric tons) facility during a 24-hour period; for grab samples, the daily value is the arithmetic or flow-weighted total mass or average concentration found in a series of at least four grab samples taken over the operating hours of the facility during a 24-hour period. If you measure more than one daily value for a pollutant and those values are representative of your waste stream, you must report them. You must describe your method of testing and data analysis.

You also must determine the average of all values within the last year and report the concentration and mass under the "Long Term Avg. Values" columns (column 2-c, Part A, and column 3-c, Parts B and C), and the total number of daily values under the "Number of Analyses" columns (column 2-d, Part A, and columns 3-d, Parts B and C). Also determine the average of all daily values taken during each calendar month, and report the highest average under the "Max. 30-day Values" columns (column 2-c, Part A, and column 3-b, Parts B and C).B. Sampling The collection of the samples for the reported analyses should be supervised by a person experienced in performing sampling of industrial wastewater.

Any specific requirements contained in the applicable analytical methods should be followed for sample containers, sample preservation, holding times, the collection of duplicate samples, etc. The time when you sample should be representative of your normal operation, to the extent feasible, with all processes which contribute wastewater in normal operation, and with your treatment system operating properly with no system upsets. Samples should be collected from the center of the flow channel, where turbulence is at a maximum, at a site specified in your present permit, or at any site adequate for the collection of a representative sample. Sampling for metals that are hardness-dependent shall also include sampling for hardness.For pH, temperature, cyanide, total phenols, residual chlorine, oil and grease, and fecal coliform, grab samples must be used. For all other pollutants 24-hour composite samples must be used. However, a minimum of one grab sample may be taken for effluents from holding ponds, or other impoundments with a retention period of greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. For stormwater discharges a minimum of one to four grab samples may be taken, depending on the duration of the discharge.

One grab must be taken in the first hour (or less) of discharge, with one additional grab (up to a minimum offour) taken in each succeeding hour of discharge for discharges lasting four or more hours. The Department may waive composite sampling for any discharge point for which you demonstrate that use of an automatic sampler is infeasible and that a minimum of four grab samples will be representative of your discharge.

Grab and composite samples' are defined as follows: Grab sample: An individual sample or at least 100 milliliters collected at a randomly-selected time over a period not exceeding 15 minutes.'Sampling are periodically reviewed in fight of recntl research ot testing methods. Upon corMletion of the review, changes to sampling may be made Before slatsing mw required sampling or 3ubhtitting pal sampling to the Departmennt.

be sure that you have a current copy of 40 CFR Part 136 or Chaplet 160,'ofids Admiustative Code.DEP Form 62-620.910(5) 2CS-5 Effective November 29,1994 Composite sample: A combination of at least 8 sample -aliquots of a least 100 milliliters, collected at periodic intervals during the operating hours of a facility over a 24-hour period. The composite must be flow proportional; either the time interval between each aliquot or the volume of each aliquot must be proportional to either the stream flow at the time of sampling or the total stream flow since the collection of the previous aliquot. Aliquots, may be collected manually or automatically.

For GCIMS Volatile Organic Analysis (VOA), aliquots must be combined in the laboratory immediately before analysis.

Four (4) (rather than eight) aliquots or grab samples should be collected for VOA. These four samples should be collected during actual hours of discharge over a 24-hour period and need not be flow proportioned.

Only one analysis is required.Data from samples taken in the past may be used if all data requirement are met; sampling was done no more than three years before submission; and all data are representative of the present discharge.

Among the factors which would cause the data to be unrepresentative are significant changes in production level; changes in raw materials, processes, or final products; and changes in wastewater treatment.

When EPA promulgates new analytical methods in 40 CFR Part 136, EPA will provide information as to when you should use the new methods to generate data on your discharges.

The Department may promulgate new methods in Chapter 160, Florida Administrative Code, with the date when the new methods are to be used. Always be sure you have current copies of these two documents before you take samples or submit sampling data to the Department.

If you have submitted data from past sampling, the Department may request additional information, including current quantitative data, if it is determined to be necessary to assess your discharges.

C. Analysis You must use test methods promulgated in 40 CFR Part 136 or Chapter 160, Florida Administrative Code; however, if none has been promulgated for a particular pollutant, you may use any suitable method for measuring the level of the pollutant in your discharge if you submit a description of the method or a reference to a published method. Your description should include the sample holding time, preservation techniques, and the quality control measures which you used. If you have two or more substantially identical discharge points, you may request permission from the Department to sample and analyze only one point and submit the results of the analysis for other substantially identical points. If your request is granted by the Department, or a separate sheet attached to the application form identify' which point you did test, and describe why the other points you did not test are substantially identical to the point which you did test.D. Reportinp, of Intake Data You are not required to report data under the "Intake" columns unless you wish to demonstrate your eligibility for a "net" effluent limitation for one or more pollutants, that is, an effluent limitation adjusted by subtracting the average level of the pollutant(s) present in your intake water. To demonstrate your eligibility, under the "Intake" columns report the average of the results of analyses on your intake water (If your water is treated before use. test the water after it is treated), and discuss the requirements for a new limitation with the appropriate district office.Part VII-A Part VII-A must be completed by all applicants for all discharge points including discharges of non-contact cooling water or storm runoff. However, at your request, the Department may waive the requirement to test for one or more of these pollutants, upon a determination that available information is adequate to support issuance of the permit with less stringent reporting requirements for these pollutants.

Use composite samples for all pollutants in this Part except use grab samples for pH. and temperature.

See the discussion in General Instructions to item VII for definitions of the columns in Part A. The"Long Term Avg. Values" column (column 2-c) and "Max. 30-day Values" column (column 2-b) are not compulsory but should be filled out if data are available.

DEP Form 62-620.910(5) 2cs-6 Efrfid~e Noyonbe, 29. 1994 Part VII-B Part VII-B must be completed by all applicants for all discharge points, including points containing only non-contact cooling water or storm runoff. You must report quantitative data if the pollutant(s) in question is limited in an effluent limitation either directly or indirectly but expressly through a limitation on an indicator (e.g., use of TSS as an indicator to control the discharge of iron and aluminum).

For other discharged pollutants you must provide quantitative data or explain-their presence in your discharge.

The Department will consider a request to eliminate the requirement to test for pollutants for an industrial category or subcategory.

Your request must be supported by data representative of the industrial category or subcategory in question.

The data must demonstrate that individual testing for each applicant is unnecessary, because the facilities in the category or subcategory discharge substantially identical levels of the pollutant or discharge the pollutant uniformly at sufficiently low levels. Use composite samples for all pollutants you analyze for in this part, except use grab samples for residual chlorine, oil and grease, and fecal coliform.

The "Long Term Avg. Values" column (column 2-c) and"Max. 30-day Values" column (column 2-b) are not compulsory but should be filled out if data are available.

Part VII-C Table 2CS-2 at the end of these instructions lists 34 primary industry categories.

For each discharge point, if any of your processes which contribute wastewater falls into one of those categories, you must mark "X" in "Testing Required" column (column 2-a) and test for (1) all of the toxic metals, cyanide, and total phenols; and (2) the organic toxic pollutants contained in Table 2CS-3 as applicable to your category.

The organic toxic pollutants are listed by GC/MS fractions on pages VII-4 to VII-IO in Part VIJ-C. The inclusion of total phenols in Part VII-C is not intended to classify total phenols as a toxic pollutant.

When you determine which industry category you are in to find your testing requirements, you are not determining your category for any other purpose and you are not giving up your right to challenge your inclusion in that category before your permit is issued. For all other cases (secondary industries, non-process wastewtater discharge points, and GC/MSfractions that are not required), you must mark "X" in either the "Believed Present" column or the "Believed Absent" column for each pollutant.

You must report quantitative data as follows: For every pollutant you know or have reason to believe is present in your discharge in concentrations of 10 ppb or greater;For acrolein; acrylonitrile; 2,4 dinitrophenol; and 2-methyl-4,6 dinitrophenol where you expect these four pollutants to be discharged in concentrations of 100 ppb or greater; and For every pollutant expected to be discharged in concentrations less that the thresholds specified above. For pollutants in this last category, in lieu of quantitative data, you may briefly describe the reasons the pollutant is expected to be discharged.

You are required to mark "Testing Required" for dioxin if you use or manufacture one of the following compounds: (a) 2,4,5-trichlorophenoxy acetic acid, (2,4,5-T);(b) 2-(2,4,5-trichlorophenoxy) propanoic acid, (Silvex, 2,4,5-TP);(c) 2-(2,4,5-trichlorophenoxy) ethyl 2,2-dichloropropionate, (Erbon);(d) 0,0-dimethyl 0-(2,4,5-trichlorophenyl) phosphorothioate, (Ronnel);(e) 2,4,5-trichlorophenol, (TCP); or (0 hexachlorophene, (HCP).DEP Fo,.62-620.919US) 2CS-7 Effecti eNov,0nbea 29, 1994 If you mark "testing Required" or "Believed Present," you must perform a screening analysis for dioxin, using gas chromatography with an electron capture detector.

A TCDD standard for quantitation is not required.

Describe the results of this analysis in the space provided:

for example, "no measurable baseline deflection at the retention time of TCDD" or "a measurable peak within the tolerances of the retention time of TCDD." The Department may require you to perform a quantitative analysis if you report a quantitative analysis if you report a positive result.Part VII-D List any pollutants in Table 2CS-3 that you believe to be present and explain why you believe them to be present. No analysis is required, but if you have analytical data, you must report it. For discharges of the hazardous substances listed in Table 2CS-4, you may be exempt from the reporting requirements of section 311 of the Clean Water Act. Please contact the Department for information.

Item VIII Thisrequirement applies to current use or manufacture of a toxic pollutant as an intermediate or final product or by-product.

TheDepartment may waive or modify the requirement if you demonstrate that it would be unduly burdensome to identify each toxic pollutant and the Department has adequate information to issue your permit. You may not claim this information as confidential; however, you do not have to distinguish between use or production of the pollutants or list the amounts.Item IX This item is self explanatory.

Item X This item is self explanatory.

Item XI This item is self explanatory.

Item XII There are severe penalties for submitting false information on this application form. Chapter 62-620, Florida Administrative Code, requires, in addition to the certification provided by a professional engineer, a certification from the owner or responsible authority of the facility as follows: A. For a corporation:

by a responsible corporate official.

For purposes of this section, a responsible corporate official means (1) a president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy- or decision-making functions for the corporation; or (2) the manager of one or more manufacturing, production or operating facilities employing more than 250 person or have gross annual sales or expenditures exceeding

$25 million (in second-quarter 1980 dollars), if authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures.

B. For a partnership or sole proprietorship:

by a general partner or the proprietor, respectively; or C. For a municipality, State, Federal, or other public agency: by either a principal executive officer or ranking elected official.

A principal executive officer includes the chief executive officer of the agency or a senior executive officer having the responsibility for the overall operations of a principal geographic unit of the agency, for example, a regional or district administrator.

DEP Form 62-620.910(5) 2CS-8 Effective Novembeo 29, 1994 TABLE 2CS-1 CODES FOR TREATMENT UNITS PHYSICAL TREATMENT PROCESSES I-A Ammonia Stripping I -N Microstraining 1-B Dialysis 1-0 Mixing I-C Diatomaceous Earth Filtration 1-P Moving Bed Filters 1-D Distillation I-Q Multimedia Filtration I-E Electrodialysis I-R Rapid Sand Filtration I-F Evaporation I-S Reverse Osmosis (Hyperfiltration)

I-G Flocculation I -T Screening I-H Flotation 1-U Sedimentation (Settling) 1-I Foam Fractionation I-V Slow Sand Filtration l-i Freezing I-W Solvent Extraction I-K Gas-Phase Separation I-X Sorption I-L Grinding (Comminutors)

I-Y Percolation Pond I-M Grit Removal CHEMICAL TREATMENT PROCESSES 2-A Carbon Adsorption 2-G Disinfection (Ozone)2-B Chemical Oxidation 2-H Disinfection (Other)2-C Chemical Precipitation 2-I Electrochemical Treatment 2-D Coagulation 2-1 Ion Exchange 2-E Dechlorination 2-K Neutralization 2-F Disinfection (Chlorine) 2-L Reduction BIOLOGICAL TREATMENT PROCESSES 3-A Activated Sludge 3-E Pre-Aeration 3-B Aerated Lagoons 3-F Spray Irrigation/Land Application DEP Fom 62.620.91I(45)

Eff~fi-N.-b,~

29.1994 2CS-9 Table 2CS-1, Codes for Treatment Units contd.3-C Anaerobic Treatment 3-G Stabilization Ponds 3-D Nitrification-Denitrification 3-H Trickling Filter OTHER PROCESSES 4-A Discharge to Surface Water 4-C Reuse/Recycle of Treated Effluent 4-B Ocean Discharge Through Outfall 4-D Underground Injection SLUDGE TREATMENT AND DISPOSAL PROCESSES 5-A Aerobic Digestion 5-M Heat Drying 5-B Anaerobic Digestion 5-N Heat Treatment 5-C Belt Filtration 5-0 Incineration 5-D Centrifugation 5-P Land Application 5-E Chemical Conditioning 5-Q Landfill 5-F Chlorine Treatment 5-R Pressure Filtration 5-G Composting 5-S Pyrolysis 5-H Drying Beds 5-T Sludge Lagoons 5-I Elutriation 5-U Vacuum Filtration 5-J Flotation Thickening 5-V Vibration 5-K Freezing 5-W Wet Oxidation 5-L Gravity Thickening TABLE 2CS-2 TESTING REQUIREMENTS FOR ORGANIC TOXIC POLLUTANTS INDUSTRY CATEGORY INDUSTRY CATEGORY GC/MS FRACTION'Volatile Acid Bas Pesticide e/Neutral Adhesives and sealants X X X Aluminum forming X X X Auto and other laundries X X X X Battery manufacturing X X Coal mining X X X X DEP Fo-m 62-620.910(5)

Effective Novemibe 29, 1994 2CS- 10 Table 2CS-2, Testing Requirements for Organic Toxic Pollutants Industry Category contd.Coil coating X X X Copper forming X X X Electric and electronic compounds X X X X Electroplating X X X Explosives manufacturing X X Foundries X X X Gum and wood chemicals X X X X Inorganic chemicals manufacturing X X X Iron and steel manufacturing X X X Leather tanning and finishing X X X X Mechanical products manufacturing X X X Nonferrous metals manufacturing X X X X Ore mining X X X X Organic chemicals manufacturing X X X X Paint and ink formulation X X X X Pesticides X X X X Petroleum refining X X X X Pharmaceutical preparations X X X Photographic equipment and supplies X X X X Plastic and synthetic materials manufacturing X X X X Plastic processing X Porcelain enameling X X X Printing and publishing X X X X Pulp and paperboard mills X X X X Rubber processing X X X Soap and detergent manufacturing X X X Steam electric power plants X X X Textile mills X X X X Timber products processing X X X X'The pollutants in each fraction are listed in Item VIl-C. X Testing required.DEP Form~ 62,1.20.910(5)

Effi,e N-.mb 29.,1994 2CS-II TABLE 2CS-3 TOXIC POLLUTANTS AND HAZARDOUS SUBSTANCES REQUIRED TO BE IDENTIFIED BY APPLICANTS IF EXPECTED TO BE PRESENT Toxic Pollutant Asbestos Hazardous Substances Acetaldehyde Allyl alcohol Allylchloride Amyl acetate Aniline Benzonitrile Benzyl chloride Butyl acetate Butylamine Captan Carbary)Carbofuran Carbon disulfide Chlopyrifos Coumpahos Cresol Crotonaldehyde Cyclohexane 2,4-D (2,4-Dichlorophinoxyacetic acid)Diazinon Dicamba Dichlobenil Dichlone Hazardous Substances 2,2 Dichloropropionic acid Dichlorvos Diethyl amine Dimethyl amine Dintrobenzene Diquat Disulfoton Diuron Epichlorohydrin Ethion Ethylene diamine Formaldehyde Furfural Guthion Isoprene Isopropanolamine dodecylbenzenesultbnate Kelthane Kepone Malathion Mercaptodimethur Methoxychlor Methyl mercaptan Methyl methacrylate Methyl parathion Mevinphos Mexacarbate Monoethyl amiine Hazardous Substances Monomethyl amine Naled Naphthenic acid Nitrotoluene Parathion Phenolsulfonate Phosgene Propargite Propylene oxide Pyrethrins Quinoline Resorcinol Strontium Strychnine 2,4,5-T (2,4,5-Trichlorophenoxyacetic acid)TDE (Terochlorodiphenyl ethane)2,4,5-TP [2-(2,4,5-Trichlorophenoxyl)propanic acide]Trichlorofon Triethanolamine dodecylbenzenesulfonate Triethylamine Uranium Vanadium Vinyl acetate Xylene Xylenol Zirconium DEP Form 62-620.910(5)

Effeciive November 29, 1994 2CS- 12

1. Acetaldehyde

2. Acetic acid 3. Acetic anhydride 4. Acetone cyanohydrin

5. Acetyl bromide 6. Acetyl chloride 7. Acrolein 8. Acrylonitrile

9. Adipic acid 10. Aldrin 1I. Allyl alcohol 12. Alyll chloride 13. Aluminum sulfate 14. Ammonia 15. Ammonium acetate 16. Ammonium benzoate 17. Ammonium bicarbonate

18. Ammonium bichromate

19. Ammonium bifluoride

20. Ammonium bisulfite 21. Ammonium carbamate 22. Ammonium carbonate 23. Ammonium chloride 24. Ammonium chromate 25. Ammonium citrate 26. Ammonium fluoroborate

27. Ammonium fluoride 28. Ammonium hydroxide 29. Ammonium oxalate 30. Ammonium silicofluoride

31. Ammonium sulfamate 32. Ammonium sulfide 33. Ammonium sulfite 34. Ammonium tartrate 35. Ammonium thiocyanate

36. Ammonium thiosulfate

37. Amyl acetate 38. Aniline 39. Antimony pentachloride

40. Antimony potassium tartrate 41. Antimony tribromide

42. Antimony trichloride

43. Antimony trifluoride

44. Antimony trioxide 45. Arsenic disulfide 46. Arsenic pentoxide 47. Arsenic trichioride

48. Arsenic trioxide TABLE 2CS-4 ELAZARDOUS SUBSTANCES

49. Arsenic trisulfide

50. Barium cyanide 51. Benzene 52. Benzoic acid 53. Benzonitrile

54. Benzoyl chloride 55. Benzyl chloride 56. Beryllium chloride 57. Beryllium fluoride 58. Beryllium nitrate 59. Butylacetate

60. n-Butylphthalate

61. Butylamine

62. Butyric acid 63. Cadmium acetate 64. Cadmium bromide 65. Cadmium chloride 66. Calcium arsenate 67. Calcium arsenite 68. Calcium carbide 69. Calcium chromate 70. Calcium cyanide 71. Calcium dodecylbenzenesulfonate

72. Calcium hypochlorite

73. Captan 74. Carbaryl 75. Carbofuran

76. Carbon disulfide 77. Carbon tetrachloride

78. Chlordane 79. Chlorine 80. Chlorobenzene

81. Chloroform

82. Chloropyrifos

83. Chlorosulfonic acid 84. Chromic acetate 85. Chromic acid 86. Chromic sulfate 87. Chromous chloride 88. Cobaltous bromide 89. Cobaltous formate 90. Cobaltous sulfamate 91. Coumaphos 92. Cresol 93. Crotonaldehyde

94. Cupric acetate 95. Cupric acetoarsenite

96. Cupric chloride 97. Cupric nitrate 98. Cupric oxalate 99. Cupric sulfate 100. Cupric sulfate ammoniated 101. Cupric tartrate 102. Cyanogen chloride 103. Cyclohexane 104. 2,4-D acid (2,4-Dichlorophenoxyacetic acid)105. 2,4-D esters (2,4-Dichlorophenoxyacetic acid esters)106. DDT 107. Diazinon 108. Dicamba 109. Dichlobenil 110. Dichlone 111. Dichlorobenzene 112. Dichloropropane 113. Dichloropropene 114. Dichloropropene-Dichloropropane mix 115. 2,2-Dichloropropionic acid 116. Dichlorvos 117. Dieldrin 118. Diethylamine 119. Dimethylamine 120. Dinitrobenzene 121. Dinitrophenol 122. Dinitrotoluene 123. Diquat 124. Disulfoton 125. Diuron 126. Dodecylbenzesulfonic acid 127. Endosulfan 128. Endrin 129. Epichlorohydrin 130. Ethion 131. Ethylbenzene 132. Ethylenediamine 133. Ethylene dibromide 134. Ethylene dichloride 135. Ethylene Diaminetetracetic acid (EDTA)136. Ferric ammonium citrate 137. Ferric ammonium oxalate 138. Ferric chloride 139. Ferric fluoride 140. Ferric nitrate DEP Form,62-620.910(5)

Effective November 29, 1994 2CS- 13 141. Ferric sulfate 142. Ferrous ammonium sulfate 143. Ferrous chloride 144. Ferrous sulfate 145. Formaldehyde 146. Formic acid 147. Fumaric acid 148. Furfural 149. Guthion 150. Heptachlor 151. Hexachlorocyclopentadiene 152. Hydrochloric acid 153. Hydrofluoric acid 154. Hydrogen cyanide 155. Hydrogen sulfide 156. Isoprene 157. Isopropanolamine dodecylbenzenesulfonate 158. Kelthane 159. Kepone 160. Lead acetate 161. Lead arsenate 162. Lead chloride 163. Lead fluoborate 164. Lead fluorite 165. Lead iodide 166. Lead nitrate 167. Lead stearate 168. Lead sulfate 169. Lead sulfide 170. Lead thiocyanate 171. Lindane 172. Lithium chromate 173. Malathion 174. Maleic acid 175. Maleic anhydride 176. Mercaptodimethur 177. Mercuric cyanide 178. Mercuric nitrate 179. Mercuric sulfate 180. Mercuric thiocyanate 18 1. Mercurous nitrate 182. Methoxychlor 183. Methyl mercaptan 184. Methyl methacrylate 185. Methyl parathion 186. Mevinphos 187. Mexacarbate 188. Monoethylamine 189. Monomethylamine HAZARDOlUS SUBSTANCES (conti.)190. Naled 191. Naphthalene 192. Naphthenic acid 193. Nickel ammonium sulfate 194. Nickel chloride 195. Nickel hydroxide 196. Nickel nitrate 197. Nickel sulfate 198. Nitric acid 199. Nitrobenzene 200. Nitrogen dioxide 20 1. Nitrophenil 202. Nitrotoluene 203. Paraformaldehyde 204. Parathion 205. Pentachlorophenol 206. Phenol 207. Phosoene.208. Phosphoric acid 209. Phosphorus 210. Phosphorus oxychloride 211. Phosphorus pentasulfide 212. Phosphorus trichloride 213. Polychlorinated biphenyls (PCB)214. Potassium arsenate 215. Potassium arsenite 216. Potassium bichromate 217. Potassium chromate 218. Potassium cyanide 219. Potassium hydroxide 220. Potassium permanganate 221. Propargite 222. Propionic acid 223. Propionic anhydride 224. Propylene oxide 225. Pyrethrins 226. Quinoline 227. Resorcinol 228. Selenium oxide 229. Silver nitrate 230. Sodium 231. Sodium arsenate 232. Sodium arsenite 233. Sodium bichromate 234. Sodium bifluoride 235. Sodium bisulfite 236. Sodium chromate 237. Sodium cyanide 238. Sodium dodecylbenzensulfonate 239. Sodium fluoride 240. Sodium hydrosulfide 241. Sodium hydroxide 242. Sodium hypochlorite 243. Sodium methylate 244. Sodium nitrate 245. Sodium phospate (dibasic)246. Sodium phosphate (tribasic) 247. Sodium selenite 248. Strontium chromate 249. Strychnine 250. Styrene 251. Sulfuric acid 252. Sulfur monochloride 253. 2,4,5-T acid (2,4,5-Trichlorophenoxy acetic acid)254. 2,4,5-T amines (2,4,5-Trichlorophenoxy acetic cid amines)255. 2,4,5-T esters (2,4,5-Trichlorophenoxy acetic cid esters)256. 2,4,5-T salts (2,4,5-Trichlorophenoxy acetic acid salts)257. 2,4,5-TP acid (2,4,5-Trichlorophenoxy propanoic acid)258. 2,4,5-TP acid esters (2,4,5-Trichlorophenoxy propanoic acid esters)259. TDE (Tetrachlorodiphenyl ethane)260. Tetraethyl lead 261. Tetraethyl pyrophosphate 262. Thallium sulfate 263. Toluene 264. Toxaphene 265. Trichlorofon 266. Trichloroethylene 267. Trichlorophenol 268. Triethanolamine dodecylbenzenesulfonate 269. Triethylamine 270. Trimethylamine 271. Uranyl acetate 272. Uranyl nitrate 273. Vanadium pentoxide 274. Vanadyl sulfate 275. Vinyl acetate 276. Vinylidene chloride 277. Xylene 278. Xylenol 279. Zinc acetate 280. Zinc ammonium chloride DEP F.,.,62-620.910(5)

Effwclive Nobe 29. 1994 2CS-14 HAZARDOUS SU`BSTANCES (Contd.)281. Zinc borate 282. Zinc bromide 283. Zinc carbonate 284. Zinc chloride 285. Zinc cyanide 286. Zinc fluoride 287. Zinc formate 288. Zinc hydrosulfite 289. Zinc nitrate 290. Zinc phenolsulfonate 291. Zinc phosphide 292. Zinc silcofluoride 293. Zinc sulfate 294. Zirconium nitrate 295. Zirconium potassium fluoride 296. Zirconium sulfate 297. Zirconium tetrachloride C, DEP Form 62-620.91015)

Eflecvire No-enb. 29. 1994 2CS-15 FORM 2CS WASTEWATER APPLICATION FOR PERIN4T TO DISCHARGE PROCESS WASTEWATER FROM NEW OR EXISTING INDUSTRIAL WASTEWATER FACILITIES TO SURFACE WATERS Facility I.D. Number: FL0002208 Please print or type information in the appropriate areas.I OUTFALL LOCATION For each outfall, list the X,Y coordinates and the name of the receiving water.(latitude/longitude to the nearest 15 seconds)A. Outfall B. Latitude C. Longitude D. Name of Receiving Water No. (List) Deg. Min. Sec. Deg. Min. Sec.D-001 27 21 05 80 14 26 Atlantic Ocean 1-003 27 20 57 80 14 48 Plant Discharge Canal 1-005 27 20 59 80 14 43 Plant Discharge Canal 1-007 27 20 52 80 14 41 Plant Intake Canal 1-008 27 20 36 80 14 28 Plant Intake Canal ,H1 OUTFALL DESIGN A. Outfall B. Design Configuration and C. D. E. Elevation F. Receiving No. (List) Construction Materials Distance Diameter of Discharge Water Depth from shore Invert (MSL) at POD (MSL)D-001 Y-Port Diffuser Reinforced Concrete Pipe 1500 ft 12 ft -36 ft -42 ft +/-Multi-Port Diffuser Rienforced Concrete Pipe 1959 -3375 ft 16 ft -27 to -38 fl -33 to -44 ft +L-1-003 Low Volume Waste-Liquid Radiation Waste <75 ft from 3.5 in N/A -12 ft +/-Stainless Steel Pipe canal shore 1 1-005 Low Volume Waste-Steam Generator Blowdown <75 ft from 4 in N/A -12 ft +1-Two Stainless Steel Pipe Unit 1&2 canal shore 1-007 Screen Wash Water On canal 3 ft +9 ft -30 ft +/-Two concrete sluiceways Unit 1 &2 Shoreline 1-008 South East Evaporation/

Percolation Basin On canal Pipe Drain N/A -30 ft I_______ _ I__ Shoreline I I 1 _ _ _DEP Fon,,62-620.910(5)

Eff-fiw' N-ono,* 29. 1994 2CS-16 Facility I.D. Number: FL 0002208 HI RECEIVING WATER INFORMATION For each surface water that will receive effluent, supply the following in'formation:

A. Name of Receiving Water B. Check One C. D. Type of Classification Receiving Water Fresh Salt or Brackish (See Ch.62-302, F.A.C.) (canal, river, lake, etc.)Atlantic Ocean E" E Ill-Marine Open Waters_ _ _ _ _ _ _ _ _ _ El Eli __El El_ _ _ _ _ _El 1:_ _ _ _ _ _E. Minimum 7-day 1 0-year low flow of the receiving water at each outfall I(if appropriate).

F. Identify' and describe the flow of effluent from each outfall to a major body of water. A suitably marked map or aerial photograph may be used.G. Do you request a mixing zone under Rule 62-4.244, F.AC.? If yes, for what parameters or pollutants?

IV FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES A. Attach a line drawing showing the water flow through the facility.

Indicate sources of intake water, operations contributing wastewater to the effluent, and treatment units labeled to correspond to the more detailed descriptions in Item B. Construct a water balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls.

If a water balance cannot be determined (e.g., for certain mining activities), provide a pictorial description of the nature and amount of any sources of water and any collection or treatment measures.B. For each outfall, provide a description of: 1. All operations contributing wastewater to the effluent;, including process wastewater, sanitary wastewater, cooling water, and stormwateir runoff;2. The average flow contributed by each operation; and 3. The treatment received by the wastewater.

Use the space on the next page. Continue on additional sheets, if necessary.

DES' Form 62-620.91%tS) 2CS-17 Effective November 29. 1994 IV B. Contd.Facility I.D. Number: FLOO02208 (1) (2) Operation(s)

Contributing Flow (3) Treatment Outfall No. (a) Operation (list) (b) Avg. Flow (a) Description (b) List Code from (List) & Units Table 2CS-1 D-001 Units I & 2 Once-Through Cooling 1487 MGD Ocean Discharge 4-B Water and Auxiliary Cooling Water 1-003 Low Volume Waste 0.004 MGD Microstraining I-N Liquid Radiation Waste Ion Exchange 2-4 Settling 1-U Neutralization 2-K 1-005 Low Volume Waste 0.011 MGD ]on Exchange 2-J Steam Generator Blowdown Settling I-U Microstraining I-N Neutralization 2-K 1-007 Intake Screen Wash 0.011 MGD 1-008 SE Evaporation/Percolation Basin 0.019 MGD Sedimentation (Settling) 1-U Evaporation I-F Percolation 1 -Y 1-06BAl-06C Former Fuel Oil Storage Area Runoff! .055 MGD Non-Industrial Storm Water to Mangrove Area DEP Fo~n,62-620 910(5)Effc~tiv Nowmbcm 29. 1994 2CS-18 IV Contd.Facility I.D. Number: FLOO02208 C. Except for storm runoff, leaks, or spills, are any of the discharges described in Items lI-A or B intermittent or seasonal?Z Yes (complete the following table) (] No (go to D. below)(3) Frequency (4) Flow (1) Outfall (2)Operation(s) (a) Days per (b) Months (a) Flow Rate (b) Total Volume No. (List) Contributing Flow(List)

Week per Yr. (in mgd) (specify with units) (c) Duration (specify avg.) (specify LongTerm Ag Ma. Dal.y Long T-er A... M_.. Daily (in days)avg.)1-G03 Low Volum- -Liquid Radialion Waste 1 12 0.024 0.032 0.024 MGD 0.032 MG <1 1-005 Low Voluon Woint- Steat Generator Blowdown 1/4 wks 12 0.365 0.776 0.365 MGD 0.776 MG I 1-007 nlao e Screen Wooh Wateo 7 12 0.254 3.053 0.254 MOD 3.053 MG <1 1.008 SE Evaporaoion/Percolaoion Boin N/A I 1.656 2.736 6.623 MGY 2.736 MG 4 D. Describe practices to be followed to ensure adequate wastewater treatment during emergencies such as power loss and equipment failures causing shutdown of pollution abatement equipment of the proposed/permitted facilities.

E. List the method(s) and location(s) of flow measurement.

V PRODUCTION A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?Z Yes (complete Item V-B) El No (go to Section VI)B. Are the limitations in the applicable guideline expressed in terms of production (or other measure of operation)?

flYes (complete Item V-C) [D No (go to Section VI)C. If you answered "yes" to Item V-B, list the quantity which represents an actual measurement of your level of production, expressed in the terms and units used in the applicable effluent guideline, and indicate the affected outfalls.I. AVERAGE DAILY PRODUCTION 2 Affected Outfalls a. Quantity per Day b. Units of Measure c. Operation, Product, Materials, Etc. (specify) (list outfall nos.)DEP Foss,62-620.910(5)

Effeimi-Nososanbee 29, 1994 2CS-19 Facility I.D. Number: FL0002208 V! IMPROVEMENTS A. Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operation of wastewater treatment equipment or practices or any other environmental programs which may affect the discharges described in this application?

This includes, but is not limited to, permit conditions, administrative or enforcement order, enforcement compliance schedule letter, stipulations, court orders, and grant or loan conditions.

E Yes (complete the following table) O No (go to Item VI-B)1. Identification of Condition, 2. Affected Outfalls 3. Brief Description

4. Final Compliance Date Agreement, Etc. a. No. b. Source of Discharge of Project a. Required B. Projected B. OPTIONAL:

You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned, and indicate your actual or planned schedules for construction.

F1 Mark "X" if description of additional control programs is attached.VII INTAKE AND EFFLUENT CHARACTERISTICS A, B, & C: See instructions before proceeding--Complete one set of tables for each outfall -- Annotate the outfall number in the space provided.

NOTE: Tables VII-A, VII-B, and VII-C are included on separate sheets number VII-I through VII-9.D. Use the space below to list any of the pollutants listed in Table 2CS-3 of the instructions, which you know or have reason to believe is discharged or may be discharged from any outfall. For every pollutant you list, briefly describe the reasons you believe it to be present and report any analytical data in your possession.

1. Pollutant

2. Source I. Pollutant

2. Source Dimethylamine 1-005 Steam Gen. Blowdown DEP Form 62-620.91005)

Effective November 29, 19WA 2CS-20 Facility I.D. Number: FL0002208 VIII POTENTIAL DISCHARGES NOT COVERED BY ANALYSIS Is any pollutant listed in Item VII-C a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or by-product?

FLYES (list all such pollutants below) Z NO (go to IX)IX BIOLOGICAL TOXICITY TESTING DATA Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last 3 years?E YES (identify the test(s) and describe their purposes below) [] NO (go to Section X)'4 inety-six hour static renewal definitive toxicity tests were conducted as required by the current NPDES -FL0002208 Permit it D-001 on October 20, 2003. These test were conducted using Mysidopsis bahia and Menidia beryllina.

FDEP preformed similar test on April 5, 2004 as a part of the five year compliance performance testing.Fhe results of both were satisfactory.

X CONTRACT ANALYSIS INFORMATION Were any of the analyses reported in Item VII performed by a contract laboratory or consulting firm?0 YES (list the name, address, telephone number, and certification number of, and pollutants analyzed by each such laboratory or firm below) []NO (go to Section XI)A. Name B. Address C. Telephone D. Pollutants Analyzed (list)(area code & no.)FPL Central Lab #E56078 5001 A Village Blvd. WPB, FL 561-640-2010 rOC, Cyanide, TKN, Phenols, BOD, Color, Surfactants (All but 1-003)General Engineering Lab, LLC 2040 Savage Rd. 843-556-8171 AI analyses for 1-003#E87156 Charleston, SC 29407 Harbor Branch Lab #E93080 5600 US Hwy I Ft. Pierce, FL 772-465-2400 Fecal Coliforms DEl' Fvm 62-6243.910(5)

Efrenive No,,mbý 29, 1994 2CS-21 Facility I.D. Number: FL0002208 XI CONNECTION TO REGIONAL POTW A. Indicate the relationship between this project and area regional planning for wastewater treatment.

List steps to be taken for this industrial wastewater facility to become part of an area-wide wastewater treatment system.The majority of the FPL, St. Lucie Plant is connected to the South Hutchinson Island Wastewater Treatment Facility, although there still exist a small number of septic tanks.XII-A CERTIFICATIONS FOR NEW OR MODIFIED FACILITIES This is to certify the engineering features of this pollution control project have been designed by me and found to be in conformity with sound engineering principles, applicable to the treatment and disposal of pollutants characterized in the permit application.

There is reasonable assurance, in my professional judgment, that the pollution control facilities, when properly maintained and operated, will discharge an effluent that complies with all applicable statutes of the State of Florida and the rules of the Department.

It is also agreed that the undersigned, if authorized by the owner, will furnish the applicant a set of instructions for the proper maintenance and operation of the pollution control facilities and, if applicable, pollution sources I- (A- .4,AA.L I .Golder Associates Inc. Cert. of Auth. No: 1670 Signature Company Name Harold A. Frediani, Jr. ...Address 3730 Chamblee Tucker Road Se) Atlanta, Georgia, 36394 S,. <)* ' (iSl Registration No.: 36394 ,, .. -Telephone No:: 770-992-2533 S ,'. Date.I certifyl 104% t #t this document and all attachments were prepared under my direction or supervision in accordance vwith 0 aptj i 'letsigned to assure that qualified personnel properly gather and evaluate the information submitted.

Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.

I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Richard L. Anderson Name & Official Title (Please type or print) Sig nature 772-467-7100 e)3[ -' ,,f.oiO Telephone No. (area code & No.) Date Signed DEP Form 62-620.910(5) 2CS-22 Effective November 29.1994 XII-B CERTIFICATIONS FOR PERMIT RENEWALS This is to certify the engineering features of this pollution control project have been examined by me and found to be in conformity with sound engineering principles, applicable to the treatment and disposal of pollutants characterized in the permit application.

There is reasonable assurance, in my professional judgment, that the pollution control facilities, when properly maintained and operated, will discharge an effluent that complies with all applicable statutes of the State of Florida and the rules of the Department.

Signature Company Name Address Name (please type)(Affix Seal) Florida Registration No.: Telephone No:: Date I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.

Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.

I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Name & Official Title (Please type or print) Signature Telephone No. (area code & No.) Date Signed DEP Form 62-620.910)(5) 2CS-23 Effdin, Nove",bea 29, 1994 Facility ID. Number: FL0002208 Outfall No. D-001 PLEASE PRINT OR TYPE ONLY: You may report some or all of this information on separate sheets instead of completing these pages. Use the same format.SEE INSTRUCTIONS.

VII. INTAKE AND EFFLUENT CHARACTERISTICS PART A -You must xrovide the results of at least one analysis for every pollutant in this table. ComnIete one table for each outfall. See instructions for additional details.1. 2. Effluent 3.. Units 4. Intake (optional Pollutant

a. Max. Daily Value b. Max. 30-day Value c. Annual Avg. Value d. No. of a. Concentration

b. Mass a. Long Term vg. Value b. No. of (1) Cone. (2) Mass (1) Cone. (2) Mass (1) Cone. (2) Mass Analyses (1) Cone. (2) Mass Analyses aCabwamBcdusx OCm Dtdn (CBD)b. Chemical Oxygen Demand (COD)e. Total Organic Carbon (TOC)d. Total Suspended Solids (TSS)e. Total Nitmgen (as N)f Total Phosphorus (as P)g. Ammonia (as N)h. Flow -actual or Value Value Value Value projected i. Flow -design Value Value Value Value j. Specific Conductivity Value Value Value Value k. Temperature (winter) Value Value Value 0 C Value 1. Temperature (summer)Value Value 115 des F Value°C Value m.. pH Min. !J Min. Max. STANDARD UNITS PART B -Mark "X" in column 2a for each pollutant you know or have reason to believe is present. Mark "X" in column 2b for each pollutant you believe to be absent. If you mark column 2a for any pollutant which is limited either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant.

For other pollutants for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge.

Complete one table for each outfall. See the instructions for additonal details and requirements.

2. Mark "X" 3. Effluent 4. Units 5. Intake (optional3

1. Pollutant and CAS a. be- b. be a. Maximum Daily b. Max. 30-day Value c. Long Term Avg. d. No. of a. Cone. b. Mass a. Long Term Avg. b. No. of No. (if available) lieved lieved Value (if available)

Value (if available)

Analyses Value Analyses present absent (1) Cone... (2) Mass (1) Cone. (2) Mass (1) Cone. (2) Mass (1) Cone. (2) Mass a. Bromide El E0 (24949-67-9)

b. Chlorine, E0 1]Total Residual c. Color 0 0 d. Fecal Coliform 0 0 e. Fluoride 0] 0 " (16984-48-8)

f. Nitrate-Nitrite 0 01 (as N) I _ _ I VII-1 DER Form 62-620.910(5)2CS, Effective November 29, 1994

Item VII-B Contd.Facility ID. Number Outfall No.2. Mark "X" 3. Effuent 4, Units 5. Intake (optional)

I. Pollutant and CAS a be- b. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Cone. b. Mass a. Long Term Avg. Value b. No. of No. (ifavailable) lieved liened (if available) (if available)

Analyses Analyses present absent (I) Cone. (2) Mass (I) Conc. (2) Mass (1) Cone. (2) Mass (I) Conc. (2) Mass g. Nitrogen.

Total [ 0 Organic (as N)h. Oil and grease 0 D]i. Phosphors, Total 0 0 (as P) (7123-14-0)

j. ..adaea*,v"ty

.,.... ..: .. ..." .(I) Alpha, Total 0-(2) Beta. Total 0 0 (3) Radium. Total [(4) Radium 226, Total 0 0 k. Sulfate (as SO 4) 0 0 (14808-79-8)

I. Sulfide (as S) [] 0 nx Sulfite (as SOO) 0 [(14265-45-3)

n. Surfactants 0 D]o. Aluninuns.

Total 0 0 17429-90-5)

p. Barium. Total 0 03 (7440-39-3) q, Boron. Total 0 [(7440-42-8)

r. Cobalt. Total " (7440-48-4)

s. Iron. Total (7439-89-6)

1. Maagnesium.

Total (7439-95-4)

u. Molybdenum, Total 0 [(7439-98-7)

s. Manganese, Total Q [(7439-96-5)

w. Tin. Total C3 (7440-31-5)

x. Titanium.

Total [(7440-32-6)

VIn-2 DER Form 62-620.910(5)2CS, Effective November 29, 1994 Facility ID. Number: Outfall No.PART C -If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions you must test for. Mark "X" in column 2a for all GC/MS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2a (secondary industries, non-process wastewater outfalls, and non-required GC/MS fractions), mark "X in column 2b for each pollutant you know or have reason to believe is present. Mark "X' in column 2c for each pollutant you believe is absent. If you mark column 2a for any pollutant, you must provide the results of at least one analysis for that pollutant.

If you mark column 2b for any pollutant, you must provide the results of at least one anlysis for that pollutnat if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrilc, 2,4,dinitrophenol, or 2-methyl-4,6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for which you mark column2b, you must either submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged.

Note that there are 7 pages to this part; please review each carefully.

Complete one table (all 7 pages) for each outfall. See instructions for additional details and requirements.

2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

I. Pollutant and CAS a , b. be- [. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Tenn Avg. Value d. No. of a. Cone. b. Mass a. Long Ten0 Avg. Value b. No. of No. (if available) teating lieved lieved (if availavailable) vailable)

Analyses Analyses:required present absent require..a.sen (2) Mass (I)Cnn...

(2) Moss (I) Con... (2) Mass (I) Cans. (2) Manss METALS. CYANIDE, AND TOTAL PHENOLS .' .. _.____ .'_---- _= "."__.I M. Antimony.

Total 0 0 E'(7440-36-0) 2M. Arsenic, Total 0 0 0 (7723-14-0) 3M, Beryllium.

Total 0 [(7440-41-7) 4M. Cadnium. Total [ [(7440-43-9)

....5M. Chromnium.

Total 1 [(7440-47-3) 6M. Copper, Total 0 0l 01 (7440-50-8) 7M. Lead, Total 0 E0 E](7439-92-1)

____ ___8M. Mercury. Total (7439-97.-.6) 9M. Nickel. Total 0 0 E0 (7440-02-0)

........I OM. Selenium, Total [] [ 0 0 (7782-49-2)

I I M. Silver, Total 0 *]*(7440-224) 12M. Thallium.

Total *] [] [](7440-28-0) 13M. Zinc, Total [] 0 (7440-66-6) 14M. Cyanide, Total [ [ [(57-12-5)15M. Phenols, Total U El 1, 0 _ 1 ....W E chlorodibenzo-P-Dioxin (1764-01-6) 1.'O I V. Acrolcin [ ] [(107-02-8) 2V. Acrylonirilc

[] [] [(107-13-1)

VIT-3 DER Form 62-620.910(5)2CS, Effective November 29, 1994 1-j Facility ID, Number: Outfall No.2. Mark "X" 3. Effucnt 4. Units 5. Intake (optional)

t. Pollutant and CAS a .b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Temi Avg. Value d. No. of a. Cone. b. Mas a. Long Term Avg. Value b. No. of No. (if available) testing livend lieved (if available) (if available)

Analyses Analyses required present absent Il) ... -(2)M as s ,0)C .-. (2) Mass (I) Co.... (2) Matss (I) C .... (2) -Mas GC/MS FRACTION -VOLATILE COMPOUNDS (continued) 3V. Benzene El 11 fl (71-43-2)4V. Bis (Chloromethyl)

Ether r (542-88-1) 5V. Brmofeorm r] 0 (75-25-2)6V. Carbon Tetrachloride r f [(56-23.5)7V Chlorobenzen¢

[ 0 El (10890.7)8V. Chiorodi-Q [beomomehanse (124-8-I)9V. Chiornethane0 0 (74-00-3)

____ _____IOV. 2-Chloro-ethylvinyl f- [Ether (I 10-75-8)I IV. Chlonoform 0 [ El (67-86-3)12V. Dichloro-11 [bromornthane (75-24-4)13V, Dichloro-1 1 El dillua, bhane(75-71-8) 14V. I, I-Dichloroethane

[ D (75.34-3)15V. 1,2-Dichloroethane 0 0 (107-06-2) 16V. LI-D lod wicricl 0 1- 0 (75-35-4),7V. 1.2,-DicoTopr o 0 0 I8V. 1.3-Dic,,npD y1ne0 0 (542-75-6) 19V. Ethylbenzene 0 [(100-41-4) 20V. Methyl Bromide " [(74-83-9)2 IV. Methyl Chloride 0 0 13 (74-87-3)22V. Methylene Chloride [ 0 0 (74-98-2)23V, l.L.2.2-Tesea-

[ [ 0 chlorocthanc (79-34-5)24V. Teteachloroethylene 0 [ '(127-18-4)

V1I-4 DER Form 62-620.910(5)2CS, Effective November 29, 1994 Facility liD. Number: Outfall No.2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available)

Analyses Analyses reequired present absent _ _ _ _ _ _ _ _ I____ __rqrd prsn abet (I) Cone. 1 2)"Mass (I) Cons. 1 2) Mass (I) Canc. (21 Mass ____________(I)

Conc. (2) Mast GC/MS FRACTION -VOLATILE COMPOUNDS (continued)

.--. (2) .. ..... (1) Cn ( Mass (1) C (. " I Cone.25V. Toluene (108-88-3)

[] El E'26V. 1.2-Trans-D [Lchro~lon(156.60-5) 27V. D D (71-55-6)28V. I.I.2-Ttichlata El 0 (7940) 1__ ___29V. Trichloroethylene

[ [ C (79-01-6)fluoromethane (75-69A-4) 3IV. Vinyl Chloride .l D El (75-0 1-A) 1 = .' .:,r .. :.;! -I A. 2-Chlorophenol 0 0] [(95-57-8)2A. 2.4-Dichlorophenol

[] [(120-83-2) 3A. 2,4-Dimethylphenol 0- (](105-67-9) 4A. 4,6-Dinitro-O-Crasol El -(534-53-1) 5A. 2.4-Dinitrophenol

] [ 1" (51-28-5)

_0_____6A. 2-Nitrophenol

[ El (88-75-5)7A.

03 0 " (100-02-7) 8A P-Chloro-M-Cresol 0- El D (59-50-7) 1 9A Pentachlorophenol 0 [ [897-86-3)

____IOA Phenol 0 El El (108-95-2)

I I A 2,4.5-Trichloro-

[ [ E phenol (88-06-2)I1B. Acenaphtlun

_ -[(63-32-9)2B. Acenaphtylene 0l El T (209-96-8) 3B. Antluacecn

[]13 [(120-12-7) 4B. Benzidine 11 0] [(92-87-5)1 1 VII-5 DER Form 62-620.910(5)2CS, Effective November 29, 1994 Facility ID. Number: Outfall No.2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

1. Pollutant and CAS a .b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Cone. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (ifavailable)

Analyses Analysts required present absent (I) Conc. (2) Mass (1) Canc. (2) Mass (I) Conc. (2) Mass (1) Cone. (2) Mass 5B. Beozo (a) Antltracene (56- [] O] I-55-3) -_ __ _6B. Benwo (a) Pyrne 0 0 (50-32-8)

........7B. 3.4-Btrt,-ar-atlw 0 0 12 (20599-2)

_ _8B. Benzo (ghi) Perylene 0 [(191-24-2) 9B. Benzo (k) FIanuhmn(207-

[ O] El 08-9) __IOB. Bit (2.(. Nm D E Methane (I 11-911)I lB. Bis (2-vhloroeth

,) 0 [Ether (111-44-4) 12B. Bis (249iwxq]

r-Ether (102 I )13B. Bis (2-Ellhylhexyl) 0 0 Phthalate ( 17-81-7)14B. 4-Bromophenyl

-El 0 Phenyl Ether ( 10 1-55-3)158 Butyl Benzyl Phthalate 0 0 " (84-68-7), 16B. 2-a t fl fl 0 (91-58-7)17B. 4-Chlorophenyl

[]Phenyl Ether (7005-72-3) 18B. Chaysene [ " (218-ol-9) 0 19B. Dibenzo (ah) El E El Anthracene (53-70-3)20B. 1.2-Dithk n z El E (95-50-1)2 1 B. 1,3-Dwicrobc c [ [ 0 22B. 14-Dichlombanz-n

](106-46-7) 23B. 3.3' [] [] 1-]=(92-94-I)24B. Diethyl Phthalate 0 0 *(84.66-2) 1 25B. Dimethyl Phthalate

.. 0 E (131-1 1-3) ___ ___________

_____26B. Di-N-Butyl Phithalate 0 El E (84-74-2), 27B. 2.4-Dinitrotoluene

](121-14-2) 288. 2,6-Dinitrotoluene 0 0 [(606-20-2)

VII-6 DER Form 62-620,910(5)2CS, Effective November 29, 1994 Facility ID. Number: Outfall No.2. Mark "X" 3. Effuent 4. Units 5. Intake (optional)

I. Pollutant and CAS a. b. be- c. be- a. Maximum Daily Value b. Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conr. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing lieved lieved (if available) (if available)

Analyses Analyses required present absent (I)Cone. (2) Mass (1) Conc. (2) Mass (I) Lonc. (2) Mass (1) Con. (2)Mass 29B. Di-N-Ocryl Phthalate

[ [ U ( 117-84-0)30B 1.2-D.#wtliydia 13 11 E 31B. Fluorantshene

[ [(206-44-0) 32B. Fluorene (86-73-7) " -338. Hexachlorobenzene C El (118-74-1) 34B. Hemchlomtbrafdiene 0 [(87-68-3)35B. H 0 11 El (77-47"4)

/__36B. Hexachloroethane 0 r [(67-72-1)

)= I I 37B. Jndeno (1, 2,3-cd) [] El [Pyrene (1 9 3-39-5) __38B. Isophormne

[] [ El (78-59-1)

_____ _____ _________39B. Naphthalene El El 0 (91-20-3)40B. Niteobenzene 0 [ El (98-95-9)41iBN-Niumdnirh rim 0 03 E (62-75-9)

____42B. N-Nitrosodi-N-

[ El [Propylanine (621-64-7) 1 43B. N-Nitro-sodiplenylamine 0 El *(86-30M)44B Phenanthrec L J (85-01-8)4 5 B. Pyrene (129-00-0) 03 El []46B. ,24-Ttddwv%

l C C (12.0"82-1)

IP. Aldrin (309-00-2) 0 El El 2P. -BHC (319-.4-6) 11 11 El 3?P -BHC (319-85-7) 4P. -BHC (58-89-9) 0] 0 ]5P. -BHC (319-86.8) 0 0 [VII-7 DER Form 62-620.910(5)2CS, Effective November 29, 1994 Facility ID. Number: Outfall No.2. Mark "X" 3. Effuent 4. Units S. Intake (optional)

1. Pollutant and CAS a. b. be- c. be- a. Maximum Daily Value b, Max. 30-day Value c. Long Term Avg. Value d. No. of a. Conc. b. Mass a. Long Term Avg. Value b. No. of No. (if available) testing licved lieved (if available) (if'availablo)

Analyses Analyses required present absent (I) Conc. (2) Mass (1) Conc. (2) Mass (l) Conc. (2) Mass (l) Conc. (2) Mass 6P. Chlordane (57-74-91

)] El 7P. 4,4'-DDT (50-29-3) 0 [8P. 4A4'-DDE (72-55-9) 3 [9P. 4,4'-DDD (72-54-8) 1 [ [lOP. Dieldrin (60-57.1)

I] 0 [IIP. -Endosulfan 1: [] 0 (115.29-7)

.......12P. -Endosulfan 0J [ El (115-29-7)

_ _ 0 13P. Endosaulfan Sulfate (1031-07-8) 14P. Endrin (72-20-8) 0 [15P. Endrin Aldehyde [ 0 0 (7421-92-4) 16P. Heptachlor 0 0 D (76,44-8)

........17P. Heptachlor Epoxide 0 C](1024-57-3) 18P. PCB,-1242

[ ] [(53469-21-9) 19P. P1CB-1254 0 0] [ 0 (11097-69-I) 20P. PCB-1221 0 [(11104-28-2) 2l1P. PC.B-1232

[] C3 [(11141-16-5) 1 22P. PCB-1249 [] M (12672-29-6) 23P. PCB-1260 0 0 11 (11096-82-5) 24P. PCB-1016 01 El C (12674-11-2) 1 25P. Toxaphene L0 I I (8001-35-2) 1 1 VII-8 DER Form 62-620.910(5)2CS, Effective November 29, 1994 Antidegradation Analysis Antidearadation Considerations

-The Florida Power & Light Company St. Lucie Plant submits that all elements of the Department's antidegradation rule (Section 62-4.242, F.A.C.) are amply met in the context of this application for a permit revision to change the current instantaneous temperature'limit of 11 3F to a monthly average limit of i 15'F; and to change the current instantaneous maximum temperature rise above ambient from 30°F to a monthly average temperature rise above ambient of 30°F.0 The proposed project is important to and is beneficial to the public health, safety, and welfare.The St. Lucie Plant provides electricity, which is an essential public amenity, and also contributes substantially to employment-and the tax base in. the region. Rule 62-302.300(6), F.A.C. confirms that "private activities conducted for private purposes may be.. .in the public interest." On January 7, 2008, the Florida Public Service Commission issued an affmrnative need determination order for the expansion of the St. Lucie Plant;Order No. PSC-08-0021-FOF-EI.

Under Florida Statute 403.519, the Commission's determination of need creates a presumption of public need and necessity for the St.Lucie expansion (a.k.a. Extended Power Uprate or EPU). Additionally, the St. Lucie Plant EPU is expected to result in hundreds of millions of dollars in fuel cost savings over the life of the "uprated" plant while preventing the emission of about 500,000 tons per year of CO 2 into the atmosphere.

The proposed permit revision would result in maximizing the environmental benefits and fuel cost savings of the EPU. Accordingly, the St. Lucie Plant permit revision application clearly is associated with a project that is important and beneficial to the public health, safety, and welfare.There will be no adverse impacts on the environment or designated uses.Regarding the second and third prongs of the antidegradation test (Rule 62-4.242(1)(b)2.

and 3.), the St. Lucie Plant is aware of no basis for expecting adverse environmental consequences to the aquatic environment or impairment to recreational values or marine productivity as a result of this permit revision.

To further address this issue, FPL has enclosed as Attachment 1, the "Thermal Discharge Study" that was prepared by Golder Associates Inc. (Golder) in January 2010. In its study, Golder conducted modeling to assess potential thermal plume impacts associated with a maximum discharge temperature of 115 0 F compared to the currently permitted limit of 113 0 F. Golder also reviewed historical data on benthic organism communities in the area of the plant cooling water discharge to predict whether there are likely to be measurable changes associated with the proposed temperature increase.

Golder concluded:

"'The difference in the extent of the thermal plume attributable to the increase in discharge temperature from 113'F to 115'F is relatively small.For the Y-nozzle diffuser, the increase ranges from about 2,000 cubic feet at the highest temperature (11 1F) to about 1,000 cubic feet at the lowest temperature (96°F). For the multiport diffuser, the range is on the order of 50 cubic feet at 11 1°F to 350 cubic feet at 96°F. The heated water exiting the diffusers at 115'F would be cooled down to 96°F within about 12.5 seconds. The potential decrease in dissolved oxygen concentration due to the increase in discharge temperature is on the order of about 0.01 milligrams per liter.The proposed change in the thermal discharge will increase the temperature of a small volume of the Atlantic Ocean water column in the near vicinity of the St. Lucie Plant discharge.

The proposed thermal discharge is expected to quickly mix with the Ocean waters and is expected to interact with the bottom sediments in a similar manner as the currently permitted discharge; the heated water will float as it mixes. Fish and other motile marine organisms are able to avoid heated discharges by swimming away from their source. Fish have also been observed to be attracted to heated discharges ,without measurable harm.Benthic organism communities are sedentary and cannot avoid the changes in water temperature.

Based on the thermal modeling conducted, no measurable change in thermal exposure is anticipated for benthic organisms-because the plumeis'buoyaht and the model predicts thatit viýl float away from the sediments as it mixes. The multiport discharges are located from 7 to 9 feet above sea bottom, allowing the water to rise as it mixes with minimal interaction With benthic organisms.

The Y-nozzle discharges are at the sea bottom' but rise while mixing with ambient water within the area of the sea bottom that was excavated for the Y-nozzle diffuser installation.

Golder concludes that the potential biological impacts of the proposed ,dischargeý temperature change are minimal and not measurable."* SWIMPlan Consistency The St. Lucie Plant EPU permit revision proposal is not inconsistent with any provisions of any South Florida Water Management District SWIM Plan.* Reuse~orOther Discharge Location There is no alternative discharge location or feasible alternative that is a viable or environmentally preferable option (See Options 1, 2 and 3 below). Accordingly, this part of the test is satisfied.

Option 1. It is not feasible to increase the circulating water flow Operational Impacts: FPL's initial application for revision Penmit FL0002208 for the EPU was approved by FDEP on March 11. 2009. At that time, FPL confirmed that it had no intention of increasing circulating water flow.Based on FPL's evaluation of recent intake temperature data, consistently maintaining the once through cooling water discharge temperature below a monthly average 113'F after the.EPU Uprate would require a reduction of 3'F in the cooling water temperature rise (Delta-T).

Accomplishing this through flow enhancement would require an increase in the total cooling water flow (per Unit) from 490,600 gpm to 547,200 gpm (about 10% increased flow), and,'commnensurately an increase in pump head from 40 ft to 48 ft also would be required.

Motor horsepower (BHP) would increase from 1475 BHP, to 2000 BBP thus requiring four new circulating water pumps for each Unit. Other cooling water system components would need to be reviewed to determine if additional modifications would be required, including intake velocity caps, travelling screens, pump suction structure (sizing), chlorination system capacity, discharge canal water level (a dam may be required to prevent road flooding), etc.The increased electrical load of approximately 1.6 MWe per Unit would require two new Unit Electrical Substations (one per Unit). New motor cables and duct banks are required.The estimated cost of increasing the circulating water flow would be between $80 and $120 million.Environmental Impacts: The 10% increase in flow would result in a significant increase in the rate of entrainment of planktonic organisms.

In addition, -the parasiticload associated with the operation

'of the -new, larger pumps would result in the following incremental increase in green house gas emissions and other air emissions as the resulting parasitic load -at the St. Lucie Plant would necessarily be "made up" by. fossil fuel power plants.Pollutant Tons per year NOx 13 S02 19-,CO2 15,978 Option 2. Installation of helper cooling towers is not feasible Operational Impacts: The installation of helper cooling towers was evaluated with the design objective being to remove the additional heat resulting from the uprate and thereby maintaining capability to continue to use the current permit temperature limit of 113'F. The design studied was a mechanical draft tower that consisted of 16 cells. The specification required high efficiency drift eliminators, but even with these in place, there could be issues of salt drift and fogging of SR AlA and possibly portions of the plant. The estimated capital cost of the helper cooling towers was approximately

$95 M. There would also be significant O&M costs associated with operation and maintenance of the towers, maintenance chemicals and the electricity to run the pumps and fans (approximately 5 MWe).Environmental Impacts: As mentioned above, operatifoi of the salt water mechanical -draft cooling towers could, under certain atmospheric conditions, result in salt spray and fogging. In addition, as with Option 1, above, the parasitic load associated with the operation of pumps and fans would result in the following green house gas emissions and other air emissions as the parasitic load would be"made up" by fossil power plants: Pollutant Tons per 3 months*NOx 5 SO 2 7 CO 2 6,156* Assumes helper cooling tower would only operate as necessary to maintain current temperature limits Option 3.'There are very 'significant -environmental and -economic costs associated with reducing reactor power. and thermal output for high ocean temperatures.

to achieve compliance with current discharge permit requirements.

Operational Impacts: Review of the most recent versions of the uprate heat balances, along with analysis of the ambient ocean water temperatures in August, September, and October (2005-2009) indicate that there now is a significant possibility that derating would be required during the late summer and early fall months,to-meet-the current permitted temperature

'limits. In fact, review of the ambient ocean temperatures in this time frame, when adjusted by adding the expected uprate discharge temperature increase (28.85°F) indicated exceedences in over 200 days of operational impact at full load over the five year (2005-2009) period. (See Attachment*2)

Assuming a power reduction of 37 MWe per unit results in a 1F reduction in cooling water discharge temperature, over 7,200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of down rated production would be required resulting in lost production revenue of about $31 million over the five year period. The more recent late summer and early fall time frames of 2007 and 2009 would have been responsible for 65% of this projected consequence.

2005 2006 2007 2008 2009 Total Cost $5,183,145

$3,025,072

$8,874,173

$2,503,616

$11,110,778

$30,696,784 In addition, nuclear power plants are designed to be operated as "base'ioad"facilities.

They are brought on line after a refueling cycle and taken to full load where typically they run for 18 months (until the next refueling event), unless there is a mechanical problem, hurricane, or other operational abnormality.

Frequent load adjustments to follow fluctuations in ambient.ocean temperatures would introduce unnecessary operational complications and inefficiencies.

Environmental Impacts: Required replacement power for the load reductions described above would come from fossil plant sources, thereby resulting in increased green house gas emissions to accompany the higher cost over the base loaded nuclear power.The resultant additional green house gas emissions and other air emissions were calculated using data from the years 2005-2009 and are quantified below: 2005 2006 2007 2008. 2009 Total Mil-hr losses 61 36 105 29 231 461 NOx (tons) 56 32 95 27 210 420 S02 (tons) 83 48 141 40 312 624 CO 2 (tons) 69,597 40,619 119,159 33,617 262,992 525,985* Waste Minimization and Source Reduction Analysis Pursuant to Rule 62-4.242(1)(d)2.

The attached affidavit verifies that the required analysis has been conducted.

==

Conclusion:==

The requested permit revision would meet all requirements of Florida's water quality standards, including the antidegradation test.

GENERAL AFFIDAVIT State of Georgia 1 , County of N>A e<.-BEFORE ME, the undersi ned Notary, l 7 ' ..[name of Notary before whom affidavit is sworn], on this J. [day of month] day of U2LO, J.- [fnonth], 20_. personally appeared Harold A. Frediani, Jr. [name of affiant], known to me to be a credible person and of lawful age, who being by me first duly sworn, on his oath, deposes and says: FPL has completed a waste minimization and source reduction analysis for the St Lucie Plant Uprate Project consistent with best management practices appropriate for the type of facility or discharge proposed, as identified in Rule 62-620.100(3)(m), F.A.C., 40CFR 122.44(k), and Guidance Manual for Developing Best Management Practices (BMP), USEPA..[signature of affiant] 4 Harold A. Frediani, Jr.[typed name of affiant]3730 Chamblee Tucker Road[address of affiant, line 1]-Atlanta, GA 30341[address of affiant, line 2]Subscribed and sworn to before me, this [day of month] day of _"__--_- __[month], 20 1 Q.'LhL'[,sign u ryo"F Z"% 1b b ie .VW a r o m,_-~'[ty~pednambdf\Af~tary]

NOTARY PUBLIC My commission expires: , 20_L."J)

ATTACHMENT I