FLORIDA DEPARTMENT OF

ENVIRONMENTAL PROTECTION

BOB MARTINEZ CENTER

2600 BLAIR STONE ROAD

TALLAHASSEE, FLORIDA 32399-2400 

RICK SCOTT

GOVERNOR

JENNIFER CARROLL

LT. GOVERNOR

HERSCHEL T. VINYARD JR. 

SECRETARY

February 4, 2013 

Electronically Sent – Received Receipt Requested

Jose_Gonzalez@floridacrystals.com 

Mr. Jose Gonzalez, Vice President Industrial Operations 

New Hope Power Company 

8001 U.S. Highway 27 South 

South Bay, Florida 33493 

Re: Request for Additional Information 

File No. 0990332-021-AC (PSD-FL-196R) 

New Natural Gas Fired Boiler (Boiler D) 

Dear Mr. Gonzalez: 

We received your Prevention of Significant Deterioration (PSD) air construction permit application on January 30, 

2013 to add a fourth boiler, “Boiler D”, to the New Hope Power Company’s (NHPC) Okeelanta Cogeneration Plant. 

Boiler D will be fired primarily with natural gas, with No. 2 fuel oil used as a backup fuel. 

The Department is in the preliminary stages of reviewing the PSD application for this project. We require some 

additional information to allow the continued review of the application to proceed (see below). Additional 

information requests may be made as the review of the application continues. In accordance with Rule 62-4.055, 

Florida Administrative Code (F.A.C.), please provide the information requested below within 90 days of receiving 

this request. 

1. National Emission Standards for Hazardous Air Pollutants (NESHAP): On Page 23 of the application 

(Subsection 3.9.4), NESHAP applicability to the project is addressed. Specifically you indicate that NESHAP 

Subpart UUUUU - National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric 

Utility Steam Generating Units is not applicable to the boiler project because: 

“the new natural gas-fired boiler at NHPC will burn natural gas at greater than 10 percent of the annual 

average heat input during any 3 calendar years, or for more than 15 percent of the annual heat input during any 

calendar year. The boiler will not burn fuel oil at greater than 10 percent of the annual average heat input 

during any 3 calendar years, or for more than 15 percent of the annual heat input during any single calendar 

year. therefore, the new Boiler D will not be subject to Subpart UUUUU, which only regulates coal and oil-fired 

units.” 

You also indicate that a case-by-case Maximum Achievable Control Technology (MACT) determination in 

accordance with Code of Federal Regulation (CFR) 40 CFR 63, Subpart B is not applicable because: 

“In the absence of MACT regulations applicable to proposed Boiler D, 40 CFR 63, Subpart B, could require that 

a case-by-case MACT determination be made for the boiler. However, as demonstrated in Section 2.4, Boiler D 

will not itself be a major source of HAPs; therefore, case-by-case MACT does not apply.” 

However you fail to address the applicability of NESHAP Subpart DDDDD - National Emission Standards for 

Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters. If you feel 

Subpart DDDDD does not apply to Boiler D, please indicate the reasons why. If you feel Subpart DDDDD does 

apply to Boiler D, please indicate what requirements from the subpart (emission limits, monitoring requirement, 

etc.) are applicable to Boiler D. 

[62-4.070, F.A.C., Reasonable Assurance] 
REQUEST FOR ADDITIONAL INFORMATION 

New Hope Power Company Project No. 0990332-021-AC (PSD-FL-196R) 

Okeelanta Cogeneration Plant Addition of a fourth boiler 

Page 2 of 2 

The Department will process the application after receipt of the requested information. Rule 62-4.050(3), Florida 

Administrative Code (F.A.C.) requires that all applications for a Department permit must be certified by a 

professional engineer (P.E.) registered in the State of Florida. This requirement also applies to responses to 

Department requests for additional information of an engineering nature. For any material changes to the application, 

please include a new certification statement by the responsible official (R.O.). Rule 62-4.055(1), F.A.C. requires 

applicants to respond to requests for information within ninety (90) days or provide a written request for an additional 

period of time to submit the information. 

If you should have any questions, please contact David Read, by telephone at (850) 717-9075 or by e-mail at 

david.read@dep.state.fl.us

Sincerely, 

Syed Arif, Environmental Administrator 

Office of Permitting and Compliance 

Division of Air Resource Management 

This letter was sent to the following people by electronic mail with received receipt requested. 

cc: Mr. Jose Gonzalez, Vice President Industrial Operations, NHPC: Jose_Gonzalez@floridacrystals.com

 Mr. Dave A. Buff, P.E., Golder Associates, Inc.: dbuff@golder.com 

Mr. Matthew Capone, Director Environmental Compliance, NHPC: Mathhew_Capone@floridacrystals.com 

Ms. Linda Brien, Air Program Administrator, DEP Southeast District: Linda.Brien@dep.state.fl.us

Mr. Joe Lurix, Program Administrator, DEP Southeast District: Joe.Lurix@dep.state.fl.us 

Ms. Katy Forney, U.S. EPA Region 4: forney.kathleen@epa.gov

Ms. Heather Ceron, US EPA Region 4: ceron.heather@epa.gov