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December 2015 FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION 14-14979 RESPONSES TO COMPLETENESS COMMENTS FPL OKEECHOBEE CLEAN ENERGY CENTER SITE CERTIFICATION APPLICATION If a regional wasteivater facility becomes available in the vicinitc of OCEC 1;1!11 1, FPL shall evaluate the practic•ahility of using the regional wostelrater facility for disposal of domestic wastewater. I'RC-14. Have OCEC' s engineers looked at the feasibility of going to a "zero liquid discharge" system for the RO/NF concentrate (Water plant wastewater) such as the anion exchange system in use at Palm Coast utilities? RESPONSE: The project includes all measures required for wastewater disposal. Zero liquids discharge (ZI-D) systems are difficult to maintain resulting in system outages for routine maintenance, mayor component replacement.. and unexpected forced outages Because of these difficulties in operating a ZLD system, adding a ZLD system to the plant would not eliminate the need for the current wastewater system including the UIC wells. The ZLD system would cost approximately $20 million to install, operate and maintain on a net present value basis In addition a ZLD system would impose a significant auxiliary plant load ofapproxlmately 5 :MW and a resultant heat rate increase of 20 Btu/kWh which would result in an approximately $15 million net present value impact as compared to the current plan The overall impact to the project would be $35 million net present value which cannot beJustified by any benefits from the installation of the system IRC-15. Section 5.3: What is the age of existing 10" artesian well? Please confirm the casing is in good shape and that there are no lateral leaks of artesian water. RESPONSE: The 10" artesian well was in existence when the property was purchased by FPL. No records exist regarding the installation of the well, therefore the age is unknown. FPL is not aware of anv surveys or tests performed on the well casing, however, the well is currently permitted and in use for agricultural purposes and there are no indications of problems. IRC-16. Section 5.3.1 states "Dewatering of the surficial aquifer will have no adverse impact on water levels or water supplies in the Upper Floridan Aquifer because the two aquifer systems are hydrologically separated by almost 300 feet of a clay-rich confining unit. What effect, if any, will the "dewatering of the SAS" have on the Fort Drum Marsh Conservation Area? As noted, the SJRWMD's Fort Drum Marsh Conservation Area is located adjacent to the Site, on the eastern boundary. RESPONSE: The impacts of dewatering during construction are discussed in SCA Section 5.2 1 and the detailed calculations supporting the dewatering impact assessment are in SCA Appendix 10.8 The conclusion is that dewatering impacts will be confined to the OCEC Unit 1 area and will not adversely impact off-Site surface waters or wetlands. Dewatering impacts will be temporary and will be in an area already impacted by construction of OCEC Unit 1. Consequently, dewatering impacts will not adversely impact Fort Drum Marsh Conservation. Area that is located east of the Site IRC-17. Section 6:8 should list IRC Utilities which has 1 MGD reuse available now. Transmission logistics from IRC to OCEC remain (to be determined). RESPONSE: FPL evaluated the cost of delivering the IRC Utilities 1 MGD reuse water to OCF_.C: It was determined that it would cost more than $56 million to install the pipeline and equipment to allow use of the water at OCEC This cost does not include any additional treatment required at the existing iRC Utilities facility to meet the OCEC water quality criteria. Currently the reuse water does not meet FPL's quality needs in addition, due the small quantity of reuse water available, the reuse 14 Attachment 3 215