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December 2015 FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION 14-14979 <br /> RESPONSES TO COMPLETENESS COMMENTS <br /> FPL OKEECHOBEE CLEAN ENERGY CENTER SITE CERTIFICATION APPLICATION <br /> droplets to be introduced into the surroundings, despite the presence of drift eliminators <br /> designed to limit droplet release. This water may be in the ideal temperature range for <br /> Legionnaires' disease bacteria (LDB) growth, 20°-501C (681-1.220F). Good maintenance is <br /> necessary, both to control LDB growth and for effective operation. Does the report address <br /> either of these issues? <br /> c) OCEC Unit 1 will utilize water from the UFA, with the expected water quality resulting in <br /> deposition ranging between 2.6 and 6 kg/ha/month within 2,000 meters of the cooling towers. <br /> These values are within the range of natural background deposition and are not anticipated to <br /> result in any adverse impacts to vegetation in the vicinity. Are these figures based on virgin <br /> process water or 5th cycle concentration? <br /> RESPONSE: a) As described in SCA Section 4 6.1. intermittent shock chlorination or other <br /> oxidizing or non-oxidizing biocides will be used to prevent biofouling of the heat rejection system <br /> These biocides are added based on the waterchemistry in the cooling tower to levels that will perform <br /> their function while reducing the amount of biocides needed This reduces the concentrations in the <br /> cooling tower circulating water to minimize concentrations in cooling tower drift. The residual <br /> concentration of biocides will be at very low concentrations vpith maximum concentrations after use <br /> less than few parts per million These concentrations decrease with time until the next biocide <br /> treatment. In addition, the drift exiting the cooling tower is controlled so that the amount of drift is <br /> 20,000 times lower than the quantity water recirculated in the cooling tower The deposition of drift <br /> also is greatly reduced in distance from the cooling tower as shown in 'Table 6 1 4-3. The <br /> combinations of low biocide residual concentrations, drift control and dispersion will result in no <br /> adverse impacts to the areas surrounding the FPL property <br /> b) While the SCA does not specifically address Legionella formation in the OCEC cooling tower.. as <br /> described in SCA Section 4 6.1 biocides are used to control biofouling. Cooling tower water quality <br /> ' and its operation are critical to the overall efficiency of OCEC FPL continually measures and <br /> ' maintains water quality to mitigate formation of biofouling agents Periodic use of biocides, such as <br /> that planned for OCEC, ensures control of Legionella growth (Occupational Safety and Health <br /> t Adininistration, OSHA Technical Manual, Section 111, Chapter 7, Section V Controls; <br /> https.//w-ww.osha.gov/dts/osta/otm/otm_iii/otin_iii_7.html#5) <br /> c) The deposition analyses are based on 5 cycles of concentration. It is therefore assumed that the <br /> i concentration in the circulating eater is 5 times higher than the makeup water supplied to the cooling <br /> tower. <br /> IRC-13. If a regional WW facility becomes available at the OCEC, should connection of the <br /> facility to domestic WW be a condition of the certification/permit? <br /> RESPONSE: As stated in Section 4 5.2 of the SCA, at this time there are no regional sewage <br /> collection systems within 10-20 miles of OCEC Unit 1; nor is FPL aware of plans for such a system <br /> to be available in the foreseeable future. However, if proposed; FPL is willing to accept a condition <br /> of certification requiring FPL to evaluate connection to a regional wastewater facility for domestic <br /> wastewater. In accordance with FDEP's first determination of incompleteness suggesting that FPL <br /> propose conditions of certification where appropriate, FPI., proposes the following condition of <br /> certification. <br /> 13 Attachment 3 <br /> 214 <br />