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G OVERNOR

J ENNIFER C ARROLL
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H ERSCHEL T. V INYARD J R

. S ECRETARY

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 Deteriorati on (PSD) air construction permit application on January 30, 2013 to add a fourth boiler, “Boiler D”, to the New Hope Power Company’s (NHPC) Okeelan ta 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 in formation 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 Hazardo us 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; theref ore, case-by-case MACT does not apply.”

However you fail to addre ss the applicability of NE SHAP Subpart DDDDD - Nationa l 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 indi cate 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 f ourth 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.) regi stered 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 responsi ble 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 Presiden t 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