CCIMMESIDN P, tits-In Bidunr- Chairman 4,53 ll 3619 Elueen Paim De Timpu. FL 3351! 'En rider c-at .sg 7 ad sir-use wana sz:-is-in EIT-IETU il-ll' Shlfilt 535-B061 catill mi 'ill 1 _,gf IE 1| 9 Mu W-lflr Eirlcutivl Ftiehnrd D. .l March 1, 2011 CERTIFIED #7005 3110 0001 2078 0509 Tampa Electric Company Case 10-01 20AR0039 lvlr. Byron E-inrows, Manager . Environmental, Health de Safety Eox Tampa, FL 33601-0111 NCUTICE UF TNTENT TD TNITIATE ENFORCEMENT Dear Mr. Eturows, SUBJECT: Big Bend Station, 13031 Wyaridotte Road, Apollo Eeacb, Hillsborough County, Florida T31 12119) The Hillsborough County Environmental Protection Act, Chapter S-4-446, Laws of Florida (EPC Act), and Chapter 403, Florida Statutes, authorize and empower the Erivironmental Protection Commission of Hillsborough County (EPC) to enforce rules and regulations to protect, control, abate, and prohibit pollution in Hillsborough County, In this regard, you are hereby infomzied of the fo llowing: By letter dated December 23, 2009, Tampa Electric Company (TEC) reported an exceedance ofthe maximum 30-day rolling nitrogen oxides average emission rate at Emission Unit (EU) No. 002. TEC recorded a 0.13 maximum average emission rate at the Facility, which is above the maximum 30-day rolling pemiitted average rate of 0.12 Through correspondence between EPC staff and Facility staff it was determined that TEC exceeded the maximum 30-day rolling l'~lCIx average emission tale on December 27, 2009 through December 23, 2009, in violation of Specific Condition .raid of Air Construction Permit No. 0520039-024-AC, which incorporates Conditions 32111 and 3213 of the Second iarnendnierit to the Consent Decree, No. 99-2524 - LLS. Tampa Electric Co., and Section Rules ofthe EPC. An nglney with values of environmental stewardship, Integrity, honesty, and a eu lture of falmess and eoopuratlon. E-Mail: AN AFFIRMATIVE ACHUN - EQUAL EMPLOYER lvlr. Bvron Burrows tvlarch 1, 201 1 Page 2 of 3 Ev letter dated .lanuary 15, 2010, TEC notified EPC staff that the Big Bend Station exceeded the 3-hour rolling average omission rate for carbon monoxide (CO) at EU (Unit No. 41'-kj. TEC stated that on December 4, 2009 their facilitv's rolling CO average emission rate was 22.0 @l5% Og, in violation of the pennitted limit of 21.0 @1596 Og in violation of Specific Condition Nos. 10 and 19 of Air Construction Permit No. 0570039-040-.AC and Section Rules ofthe EPC. Bv electronic mail correspondence dated lulv 22, 2010, TEC notified EPC staff that the Big Bend Station experienced opacity eitoeetlances during maintenance on the ash feed ers for the silo associated with EU 001 [Unit 1). The documented opacity levels er-tceeded the 20% standard on July 21, 2010 at 1213 hours, 1224 hours and 1230 hours. The highest E-minute opacity averages were 27.5, 24.0 and 23.5 respectively, in violation of Rules and ., F.A.C., Facility-wide Condition No. FW4 and Specilic Condition Nos. All and A. 29 of Title Air Operation Perrnit No. You are hereby advised that the EPC staff believes that the above facts violations ofthe EPC Act and rules, and the Florida Adrnirlistrative Code, and we are Therefore obligated to pursue enforcement for correction. Show cause: Should you believe that the above information is incorrect or incomplete, you are requested to immediately show cause by providing us with any additional relevant infonnation that may indicate that the above is not a violation. In addition to correction, potential penalties for such violations include imposition of damages and civil penalties of up to $10,000 per violation. Each dav in which the above violations continue or recur constitutes a separate violation subject to enforcement Settlement without litigation: Should you wish to settle this matter amicably, the Executive Director may be able to enter into a Consent Order containing mutually agreeable terms. Such an order normallv contains conditions nocessarv to correct the violation and a settlement payment to the Pollution Recoverv Fund. ln return, the Executive Director will waive the right to proceed in court agonist von. Should von wish to resolve this matter at once, we have enclosed with this Notice a Consent Order for your consideration. This Consent Order is a draft and would become operative only if the tenns are agreed to bv both parties. lf this Order is acceptable, please sign before a notary and return within 10 dave of receipt of this Notice. lf von would like to meet wit.h stat? to discuss any issue or the re/quirements for settlement., please contact Reggie Sanford at (Sli) 622'-21500, et-:tension 1254. Mr. Byron E-u1'1'ow5 March l,2Dll Page 3 lJf3 Please mail or deliver the signed Consent Dnder to the Ai: Management Division, 3629 Queen Palm Drive, Tampa, Florida 33619, to the attention oflileggie Sanford. We anticipate that this matter l2'>>t'i1'l be resolved through settlement and appreciate your cooperation in addressing this expeditiously Sincerely, Jerry' Campbell, P.E. Director Air Management Division Enclosure cc: Cindy DEP-SW BEFORE PROTECTION- COMMISSION HILLSHOIROUCH CO UNTY ENVIRONMENTAL PROTECTION COMMISSION OF HILLSBOROUGH COUNTY, i Complainant, fa EPC FILE NO. vs. - i' TANIPA ELECTRIC CONIPANY, i Respondent. CONSENT ORDER This Consent Order is entered into between the Environmental Protection Commission of Hillsborough County and Tampa Electric Company ("Respondent"] to reach settlement of certain matters at issue between the EPC and Respondent pursuant to Chapter S4-446, as amended, Laws of Florida ("l-Iillshorongh County Environntentali Protection Act" or Act"], Chapter 403, Florida Statutes and an interagency agreement with Florida Department ot`Envircnmental Protection authorizing the EPC to act on behalf of the State. The EPC finds and the Respondent admits the following: l. The EPC is a local regulatory agency having the power and duty to protect Hillsborough County's air, soil," and water resources and to administer and enforce the Hillsborough County Environmental Protection Act, Chapter 34-4445, as amended, Laws of Florida, and the EPC rules promulgated thereunder including but not limited to Chapters l-l and l-3, Rules ofthe EPC, and also Chapter 403, FS., and the rules promulgated theretmder, specifically Title 62, Florida Administrative Code in Hillsborough County, Florida. The EPC has been sp-ccitically authorized by the DEP to enforce State rules and statutes conceming air facilities, including the subject electric power-generating facility, The EPC has jurisdiction over the matters addressed in this Consent Order, 2. Respondent is a person within the meaning of Section FS. 3. Respondent is the owner and is responsible for the operation ofthe Tampa Electric Conrparry's Big Bend Station (Facility), an electric power-generating facility. The Facility consists of four fossil-fueled steam generators, four steanr turbines, one simplecycle turbine, solid fuels, fuel oil storage tanks, fly ash, limestone, gypsurn, slag, and bottom ash storage and handling facilities. Respondenfs Facility is a Title sout'ce as defined in Rule E2-210.200, F.A.C. The Facility is also a major soruce ofthe air pollutants carbon monoxide (CC) and oxides of nitrogen The Facility is located at 13031 Wyandotte Road, Apollo Beach in Hillsborough County, section 'El' township 31 range 19 The map coordinates are UTM Zone 17, 361.23 East and 3075.10 lon l'-lorth. All of the Facility's operations are subject to the prohibitions and conditions of EPC Act- and rules promulgated thereunder, Florida Statutes and the rules promulgated thereunder, and Air Construction Permit No. 0520039-040-AC [Construction Permit 040), which expired on December 24, 2010; Air Construction Permit No. 0570039-02-L AC (Construction Permit 024), which expired on December 31, 2010; and Title Air Clperating Permit No. 0520039-039-AV (Title Permit), which expires on December 12, 2014. 4. On February 29, 2000, Respondent voluntarily entered into a settlement, Civil Action No. 99-2524 CW-T-23F - U.S. Tampa Electric Co. ("Consent with the United States of Prrnerica on behalf of the United States Environmental Protection Agency to reduce air pollution emissions from the Facility. 5. By letter dated December 2S, 2000, Respondent reported an exceedance of the maximum 30-day rolling 1'~lC'x average emission rate at Emission Unit (EU) No. 002. Respondent recorded a 0.13 maximum average emission rate at the Facility, which is above the maximum 30-day rolling permitted average rate of 0.12 Respondent stated that the selective catalytic reduction system was inoperable during the time period in question because of low tlue gas temperatures, which led to elevated l~ICtx levels. Through correspondence between EPC staff and Facility staff it was determined 2 that the Facility exceeded the maximum 30-day rolling average emission rate on December 22, 2009 through December 23, 2009, in violation of Specific Condition No. 141.16 ot" Construction Permit 024, which incorporates Conditiom 32.4. and 3213 of the Second Amendment to the Consent Decree, and Section 1-3 .2 1113), Rules ofthe EPC. 6. January T, 2010, EPC staff issued Warning Notice No. 2010-000414. to Respondent in response to the violation. T. By letter dated January 15, 2010, Respondent notified EPC .staff that the Facility exceeded the 3-hour rolling average emission rate for CCI at EU 041 (Unit No. 4.41)- Respondent stated that on Decemher 4, 2009 the Facility's rolling average CD rate was 22.0 @15% Dy, in violation ofthe permitted limit ofthe 21.0 @1594 Cy, in Specific Condition Nos. 10 and 19 of Corstruction Permit 040, and Section 1-3 .21 Rules of the EPC. S. Cin January 20, 2010, EPC staE` issued Warning Notice, No. 2010-0015151 to Respondent in response to the violation_ 9. By electronic mail correspondence dated July 22, 2010, Respondent notified EPC staff that the Facility experienced opacity exceedances during rnaintenance on the tly ash feeders for the silo associated with EU 001 (Unit 1). The documented opacity levels exceeded the 20% standard on Iuly 21, 2010 at 121 hours, 1224 hours and 1230 hours. The highest E-minute opacity averages were 27.0, 24.0 and 23.6 respectively, in violation of Rules and 52- F.A.C., Facility-wide Condition No. FW4 and Specific Condition Nos. All and A. 29 of the Title Ferrnit. 10. Hy letter dated August 22, 2010, in response to Warning Notice No. 2010-0203A issued hy EPC stat? on August 10, 2010, Respondent stated that the excess emissions were the direct result of an unavoidable equipment malfunction and therefore allowed by their Title permit. 3 ll. Having reached a resolution of the matter the EPC and the Respondent mutually agree and it is ORDERED: 12- Within 30 days of the effective date of this Consent Order, the Respondent shall submit a written plan to EPC staff for review and approval that details bow Respondent will ensure future compliance with the 30-day rolling average emission rate of 0.12 i'~lOxt'nunbtu. The plan shall include, at a minimum, speciie measures to address wet coal issues or other circumstances that would affect the operation of the selective catalytic reduction (SCR) system. The approved plan shall be implemented by Respondent upon receipt of written approval by EPC staff. The EPC-approved plan shall be automatically incorporated by reference into this Consent Order and shall be enforceable as part ofthe Consent Order. 13. Within 15 days of the effective date of this Consent Order, Respondent shall pay the EPC a total of 513,937.3 in settlement ofthe matters addressed in this Consent Order as further apportioned below. ta) This amount includes for costa and expenses incurred by the EPC during die investigation of this matter and the preparation and tracking of this Consent Order, made payable to "The Environmental Protection Commission" with the notation Costs." fb] The civil penalty in this case includes the following violations: $9,300.00 for violation of Specific Condition No. Auld of Construction Permit 024; $3,000.00 for violation of Specific Condition Nos. 10 and 19 of Construction Permit 040; and $1,500.00 for violation of Specific Condition Nos. A.l1 and A29 of the Title Permit. Thus, a total payment of $13,800.00 for civil penalties shall be rnade by check or money order, and the instrument shall be made payable to the Pollution Recovery Fund" and shall include thereon the notation "Civil Penalty" and the EPC number assigned to diis Consent Order found on the first page of this Consent Order. It lf Respondent fails to timely pay an agreed penalty or cost in full or any negotiated installment amount or if the Respondent tiles for bankruptcy, Respondent shall notify EPC within ten days of missing a payment deadline or tiling for and any unpaid balance will become immediately due and owing. 14. If any event, including administrative or judicial challenges by third parties unrelated to the Respondent, occurs which causes delay or the reasonable lilcelihood of delay, in complying with the requirements of this Coment Clrder, Respondent shall have the burden of proving the delay was or will be caused by circumstances beyond the reasonable control of the Respondent and could not have been or cannot be overcome by Respondents due diligence. Economic circumstances shall not be considered beyond the control of Respondent, nor shall the failure of a contractor, subcontractor, materialman or other agent (collectively referred to as "contractor") to whom responsibility for performance is delegated to meet contractually imposed deadlines be a cause beyond the control of Respondent, unless the cause of the contractor's late perforrnarrce was also beyond the contractor's control. Upon occurrence of an event causing delay, or upon becoming aware of a potential for delay, Respondent shall notify the EPC orally within 24 hours or by the nest working day and shall, witl'tin seven calendar days of oral notihcation to the EPC, notify the EPC in writing of the anticipated length and cause of the delay, the measures taken or to be taken to prevent or minimize the delay and the timetable by which Respondent intends to implement these measures. If the parties can agree that the delay or anticipated delay has been or will be caused by circimrstances beyond the reasonable control of Respondent, the time for pert`ormance hereunder shall be extended for a period equal to the agreed delay resulting from such circumstances. Such agreement shall adopt all reasonable measures necessary to avoid or rninimiae delay. Failure of Respondent to comply with the notice requirements of this Paragraph in a timely manner shall constitute a waiver of Respondent's right to request an extension ot" time for compliance with the requirements of this Consent Order. 5 l5 In the event of a sale, lease, or other conveyance (collectively referred to as "convey" or "conveyance") ofthe Facility or of the Property upon which the Facility is located, if all of the requirements of this Consent Order have not been tially satisfied, Respondent shall, at least 30 days prior to the conveyance of the Property or Facility, (1) notify the EPC of such conveyance, (2) provide the EPC the name and address of the purchaser, operator, or personts) in control of the Facility (collectively referred to as "new controlling party"), and (3) provide a copy of this Consent Order with all attachments and amendments to the new controlling party. Additionally, if Respondent conveys all or part of the referenced Property or Facility, Respon- dent shall immediately enter into a written agreement with the new controlling party wherein Respondent reserves the right to access the Property or Facility to complete performance of the Consent Order terms. Respondent shall remain completely responsible to the EPC for compliance with this Consent Order regardless of any conveyance, unless the new controlling party specifically assumes the Respondents responsibilities hereunder in writing and the EPC Executive Director specifically approves the assumption in writing. 16. Persons who are not parties to this Consent Order, but whose substantial interests are affected by this Consent Order, have a right, pursuant to Sections l2tl.569 and l2tl,5?, FS., to_ petition for an administrative heating on the Consent Order. The Petition must contain the information set forth below and must be tiled (received) at the EPC's Legal Department, 34529 Queen Palm Drive, Tampa, Florida 33519 within 21 days of receipt of this notice of rigl1t.s_ Failure to file a petition within the 21 days constitutes a waiver of any right such person has to an administrative hearing pursuant to Sections 120.569 and 121151 FE. The petition shall contain the following information: The name and address of each agency affected and each agency's file or identification number, if lcnown; (bfi The narne, address, and telephone number of the petitioner, the name, address, and telephone number of the petitioner's representative, if any, which shall he the address for 6 service purposes during the course of lil'1E proceeding; and an explanation of how the petitioner's substantial interests will be affected by the agency determination; (C) A statement of when and how the petitioner received notice of the agency decision (ie. - Consent Order); (cl) A statement of all disputed issues of material fact. If there are none, the petition must so indicate; A concise statement of the ultimate facts alleged, including the specific facts the petitioner contends warrant reversal or modification of die agency`s proposed action; (D A statement of the specific rules or statutes that the petitioner contends require reversal or modification of the agencv's proposed action, including an explanation of how the alleged facts relate to the specific _rules or statutes; and (gl A statement of' the relief sought by the petitioner, stating precisely the action petitioner wishes the agency to tal-te with respect to the agency's proposed action. If a petition is filed, the administrative hearing process is designed to formulate agency action. Accordingly, the EPC's final action may he ditferent from the position taken by it in this Consent Order. Persons whose substantial interests will be affected by any decision of the EPC widi regard to the subject Consent Order have the right to petition to become a party to the proceeding. The petition must conform to the requirements specified ahove and be filed (received) within 21 days of receipt of this notice in the Legal Departtnent at the above address of the EPC. Failure to petition within the allowed time name constitutes a waiver of any right such person has to request a hearing under Sections 120.569 and 12[l.57, F-S-, and to participate as a party to this proceeding. any subsequent intervention will only he at the approval ofthe presiding upon motion iled pursuant to Rule 28-106.205, Florida Administrative Code. A person vvhose substantial interests are affected by the Consent Order may file a timely petition for an administrative hearing under Sections l2ll.569 and 120.51 F.S. Mediation is not available lT. Respondent shall allow all authorized representatives of the EPC access to the Property and Facility at reasonable times for the purpose of determining oompliance with the terms of this Consent Order and the rules and statutes of the OEF and EPC. Determining compliance includes but is not limited to, taking video or photographs, inspection, record reviews, sampling, and testing. lil. All submittals and payments required by this Consent Order to be submitted to the EPC shall be sent to Reggie Sanford, EPC at 3629 Queen Palm Drive, Tampa, Florida 33619. 19. This Consent Order is a settlement ofthe EFC's civil and administrative authority arising under Florida law to resolve the matters addressed herein. This Consent Order is not a settlement of any criminal liabilities which may arise under Florida law, nor is it a settlement of any violation which may be prosecuted criminally or civilly under federal law. Entry of this Consent Order does not relieve Respondent of the need to comply with applicable federal, state or local laws, regulations or ordinances, and all applicable permits and orders issued under those laws, regulations or ordinances. This Consent Order shall not be a defense to any actions cornrnenced pursuant to said laws, regulations, ordinances, orders, or permits, ertcept as expressly described in this Consent Order. 20. The EPC hereby expressly reserves the right to initiate appropriate legal action to prevent or prohibit any violations of applicable statutes, or the rules promulgated thereunder that are not specifically addressed by the temts of this Consent Order, including but not limited to undisclosed releases, contamination or polluting conditions. 21. The terms and conditions set forth in this Consent Order may be enforced in a court of competent jurisdiction pursuant to Sections 120.69 and 403.121, Florida Statutes. Failure to comply with the terms of this Consent Order shall constitute a violation of Section 403. RS. and the EPC Act. 22. The EPC, for and in consideration of the complete and timely performance by Respondent of the obligations agreed to in this Consent Order, hereby conditionally waives its right to seek judicial imposition oi' damages or civil penalties for the violations described above up to the date ofthe filing of this Consent Order as addressed in this Consent Order. This waiver is conditional upon Respondenfs complete compliance with all the terms of this Consent Order. The Respondent acknowledges and agrees that in no event shall this Consent Order be construed to apply as a waiver by the EPC to undertake cause of action not addressed by this Consent Order. 23. Respondent is hilly aware that a violation of the terms of this Consent Order may subject Respondent to judicial imposition of damages, civil penalties up to 510,000.00 per day per violation, costs and expenses of litigation and criminal penalties. 24. No ofthe terms of this ceases oraa* sian he areaive rein reduced to writing and executed by both Respondent and the EPC, and tiled with the Clerk ofthe EPC. 25. Respondent acknowledges and waives its right to an administrative hearing pursuant to Sections 120.569 and l20.5'Ir', P.S., on the terms of this Consent Order. Respondent also acknowledges and waives its right to appeal the terms of this Consent Order pursuant to Section 12068, F.S. Respondent hereby foregoes, surrenders, waives, and disclaims any and all other hearing and appeal rights under Chapter 120, ES., or Section 9 ofthe EPC Act and any and all other suits, appeals, claims, or causes of action in any court of competent jurisdiction, including but not limited to County Court, Circuit Court, the Division of Administrative Hearings, appellate courts, or any other EPC hearing processes against the EPC and DEP arising out of or relating to the violations addressed in this Consent Order, and Respondent, and their cotutsel, further agree not to encourage or support any such actions by other parties or 9 entities to challenge this Consent Order, If Respondent is charged with violation of this Consent Order, Respondent does not waive its right to prove compliance with the terms of this Consent Order in any court of competent jurisdiction. 26. The provisions ofthe Consent Order shall apply to, inure, and be binding upon the parries and their successors and assigns, Each ofthe part.ies hereby agrees that in the event one of the parties attempts to enforce the terms of tl1is Consent Order, no defense will be raised as to the validi1.y or enforceability of this Consent Order. This Consent Order shall be construed and enforced under Florida Law. 21 All parties agree to pay their own fees and costs, including attorney's fees and costs, related to the violations addressed in this Consent Order and incurred up to the date of e:-tccution of this Consent Order, ei-:cept that Respondent shall pay for any penalties, cost, and fees agreed to in this Consent Order. I 23. The EPC, does not, by execution of this Consent Order, warrant or assert in any manner that the Respondent's compliance with this Consent Order will result in compliance with Respondents Notwithstanding the EPC's review or approval of any plans, reports, schedules, policies, or procedures prepared pursuant to this Consent Order, the Respondent and its successors and assigns shall remain solely responsible for any noncompliance with the tenns of this Consent Order, all applicable Federal, state or local laws, regulations or ordinances. 29. This Consent Order is a final order ofthe EPC pursuant to Section and it is final and effective on the date tiled with the Clerk ofthe EPC unless a Petition for ndrninistrative Hearing is tiled in accordance with Chapter lltl, PS- Upon the timely tiling of a petition this Consent Order will not be effective until farther order of the EPC. 30. Rules referenced in this Consent Order are available at and lt] FUR TI-IE RESPONDENT: DATE NAME Title I, the undersigned (name) [title] of Tampa Electric Company (company), and doing business at (address) being iirst sworn, do afiimi that I am duly authorized under the articles of incorporation and by- laws oi` (company) to bind the Respondent by my signature to this settlement and that it is my signature which Erst appears above on behalf of Respondent. Signature Title Sworn to and subscribed before me this day of 2tll_, by [printed name of F'ri'iiar1t}, who is personally lmown to me, or who produced as identification. vv1v Notary Public, State of Florida ll DCINE ANT) ORDERED this day of in Fleride. ENVIRCNMENTM, PROTECTION CUMNIISSION UF HILLSEORGUGH Richard Cre.r1'ity, Executive Director FILIINTC AND ACKNUHTLEDGEMENT FILED, nn this date, pursuant tn ?12lJ.52 Florida Statutes, with the designated EPC Clerk, receipt of which is hereby aeltnuwledged. Clerk Date Copies furnished tu: DEP-SW TECU CEI- February 25, 201] 12 Memorandum To: TEC-D Enforcement File Case Ho. lil-(ll EUARDUB From: R. Sanford, Enforcement Coordinator Date: November 16, 2010 Re: Fnalty Calculation for Consent Decree Violations 3 EPC staff has determined that exceeded the maximum 30-day tolling NCR emission rate average at EU U02 at a level of 10% above the atandmd Ln accordance with Condition VLH. 53. of the Consent Decree, a penalty ia at $300 per day per violation for each day out of compliance, was out of compliance with the Consent Decree Condition for 31 days bring their total penmtv for this violation to QEEDLH Ha Rupmlihhl TECD CIN to mm. 1_ FDR BETTLEIEHT PURPOSES UNLV 2 :nm I. .luztuil H1r1'|'| en In l|Hl'll -dlpTDHI Punmy pfmununn Anluul Humuurlponum h. I-lim 11111 11111 1111 Ihlt Emu ll Emillim ET-lldid |ml5mP'lf 15; Smgu I wpur iymlum Ernriunrn?n|: fa) Lungla arm nl Prubihlu 'vlnlatlnn Dnudpiinn rnpun nan nrnIulu|'u'ah|1urmlI 121 pm-nil: q3} pam! 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