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U.S. Environmental Protection Agency

Responses to Public Comments

Draft Greenhouse Gas PSD Air Permit for the Port Everglades Next 

Generation Clean Energy Center

November 22, 2013
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Table of Contents

Introduction.....................................................................3

EPA’s Responses to Public Comments............................3

Request for Public Hearing and Comment Period Extension. 3

Comments & EPA Responses............................................. 5

Comments Submitted by Alexandria Larson ................. 5

Comments Submitted by Sierra Club ........................... 7

Comments Submitted by Florida Power & Light.......... 18
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Introduction

The U.S. Environmental Protection Agency, Region 4 (EPA) proposed to issue a Prevention of

Significant Deterioration (PSD) permit for Greenhouse Gases (GHGs) to Florida Power & Light 

Company (FPL) for the Port Everglades Next Generation Clean Energy Center (Facility) on May 

31, 2013. The public comment period for the proposal (Proposed Permit) began on May 31, 2013, 

and closed on July 2, 2013. During the public comment period EPA took comments on the 

proposed permit.

EPA announced the public comment period through a public notice published in the Florida 

Register and Sun Sentinel (in English) on May 31, 2013, and on Region 4’s website (in English) on 

May 31, 2013. EPA also distributed the public notice to the necessary parties in accordance with 40 

CFR Part 124, including notices sent by email on May 31, 2013. Parties notified by EPA included 

agencies, organizations, and public members for whom contact information was obtained through a 

number of different methods, including requests made directly to EPA through Region 4’s website 

(or through other means) from parties seeking notification regarding permit actions in Florida, 

within the jurisdiction of Florida Department of Environmental Protection (FDEP), within Broward 

County; and other parties known to EPA that may have an interest in this action. 

During the public comment period, EPA received three comment letters and one request for a 

public hearing. Responses to the public comments received are available in the following sections 

of this document.

EPA’s Responses to Public Comments

This section summarizes all public comments received by EPA and provides our responses to those 

comments. The full text of all public comments and many other documents relevant to the permit 

can be accessed online at www.regulations.gov (Docket #EPA-R04-OAR-2013-0431) or on 

Region 4’s website at www.epa.gov/region4/air/permits/ghgpermits/porteverglades_ghg.html.

Request for Public Hearing and Comment Period Extension

One commenter, Alexandria Larson, requested a public hearing and an extension of the public 

comment period. Included below is the request and EPA’s response.

Request: Thank you for the time you recently spent on the phone discussing the Port Everglades 

greenhouse gas permit notice. It was not at all clear to me who would actually consider my request, 

therefore I am making the request in writing to you and asking you to add my comments to the 

docket and forward this request through your management to your regional administrator.

In accordance with the Published Notice of May 31, 2013 in the Sun Sentinel, I request that EPA 

actually hold the public hearing tentatively scheduled on July 2, 2013, from 4:00 pm to 7:00 pm, at 

the advertised following location: Broward County Library, 100 South Andrews Avenue, Fort 

Lauderdale, FL 33301, (954) 357-4444.

In the addition to the meeting, I request the described 30-day extension of the 30-day comment 

period to provide additional time to prepare comments and postponement on the issuance of the 
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permit of the Port Everglades PSD-EPA-4010 Permit. The public hearing will allow EPA to 

explain and for the public to understand the following matters;

EPA Response: Under 40 C.F.R. 124.12(a)(1), EPA shall hold a public hearing if the agency 

“finds, on the basis of requests, a significant degree of public interest in a draft permit(s).” 

After careful consideration of Ms. Larson’s request as well as other potential indicators of 

public interest in the draft permit, EPA determined that there is not a significant degree of 

public interest sufficient to warrant holding a public hearing.

While Ms. Larson’s hearing request identified material issues, it was the only request submitted 

to EPA and did not present information indicating that there is a significant degree of public 

interest in the draft permit. Ms. Larson did not indicate that she was submitting the request on 

behalf of anyone other than herself, and did not identify any other individual or organization 

that had expressed any interest in the draft permit or in participating in a public hearing. Nor 

did Ms. Larson offer any other information indicating that other members of the public are 

particularly interested in the issues addressed by the draft permit, specifically, the regulation of 

GHG emissions that will be generated by the plant modification. 

Other than Ms. Larson’s comment, EPA received only one other set of adverse comments. 

Those comments were submitted on behalf of Sierra Club by an attorney in Sierra Club’s 

California office and did not express interest in a public hearing. Aside from these two 

comments, EPA does not have any other information indicating public interest in this draft 

permit. The project involves modernizing the existing Port Everglades Plant by retiring four 

existing oil-fired units and replacing them with a cleaner-burning and more efficient combined 

cycle unit, which will rely primarily on natural gas. Non-GHG pollutants will not increase 

significantly and are governed by a state-issued minor new source review (NSR) permit. 

Florida received no comments from the public or the applicant on the minor NSR permit issued 

for this project. Furthermore, the project attracted very little media interest; EPA was able to 

locate only two relevant articles from a major news outlet, both of which focused primarily on 

the removal of the plant’s 1960s era smokestacks as part of the plant renovation. Finally, EPA 

received no comments suggesting that demographic factors should affect EPA’s determination 

regarding whether there is a significant degree of public interest in this GHG permit 

proceeding. Based on the specific facts of this permit proceeding, Region 4 further concluded 

that there is no need for EPA to exercise its discretion under 40 CFR 124.12(a)(2) to hold a 

hearing.

While Ms. Larson stated that a public hearing would allow EPA to explain and for the public to 

understand certain issues regarding the permit, Region 4 concluded that direct communication 

with Ms. Larson would be sufficient to clarify several of the matters of interest to her. On June 

24, 2013, and June 27, 2013, Heather Ceron, EPA Region 4’s Air Permits Section Chief, 

telephoned Ms. Larson and clarified various procedural issues. Among other things, Ms. Ceron 

described EPA’s role in permitting GHGs versus the state’s role in permitting other pollutants, 

responded to Ms. Larson’s questions regarding the availability of a petition or appeal process, 

and clarified the purpose and status of the National Oceanic and Atmospheric Administration’s 

preparation of a Biological Opinion under the Endangered Species Act. In addition, Ms. Ceron 

emailed Ms. Larson with a link to the page on EPA Region 4’s website describing EPA’s role 

in regulating GHGs in Florida. Ms Larson said she did not intend to submit additional public 

comments on the permit after these communications with Region 4 staff and withdrew her 
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request for an extension of the public comment period. (see Memo to File dated July 9, 2013

from Heather Ceron, Air Permits Section Chief) Region 4 therefore did not extend the public 

comment period. EPA considered Ms. Larson’s email requesting a hearing also to reflect her 

comments on the draft permit. 

Comments & EPA Responses

Comments Submitted by Alexandria Larson

1. Comment: Where is an explanation in the notice regarding a petition or appeal process such 

as is normally found in state permit public notices. The public notice as published is clearly 

incorrect.

EPA Response: EPA’s public notice complied with 40 CFR § 124.10, which sets forth 

the public notice requirements for EPA-issued PSD permits. After the close of the comment 

period, EPA must notify the applicant and each person who submitted written comments or 

requested notice of the final permit decision. That notice must include reference to the 

procedures for appealing EPA’s permit decision. See 40 CFR § 124.15. Consistent with the 

regulatory requirements, EPA’s notice of a final permit decision in this proceeding explains 

that the procedures governing PSD permit appeals are set forth at 40 CFR § 124.19. The 

final permit decision notice further explains that any person who filed comments on the 

draft permit may petition the Environmental Appeals Board to review any of the revised

conditions of the final permit, and that such petition must include a showing that the 

conditions in question are based on a finding of fact or law which is clearly erroneous, and

a demonstration that these same issues were raised during the comment period. Additional 

information regarding the procedure for EAB appeals is available online at 

http://www.epa.gov/eab. EPA sent the final permit determination directly to Ms. Larson, 

the permit applicant, and other interested parties.

2. Comment: What is the action about? Why are greenhouse gases regulated. It 

looks as if the state DEP already granted a permit for several million tons of 

pollutants for the same project and now EPA proposes to allow over 4 million 

more tons of pollutants from the same project. 

EPA Response: The EPA permit will regulate GHG emissions from the new combined 

cycle units at the existing Port Everglades Next Generation Clean Energy Center. GHGs are 

the aggregate of the following six gases: CO2, CH4, NOx, SF6, HFCs, and PFCs. These six 

gases, once emitted, remain in the atmosphere for decades to centuries. Thus, they become 

well-mixed globally in the atmosphere and their concentrations accumulate when emissions 

exceed the rate at which natural processes remove them from the atmosphere. The heating 

effect caused by the human-induced build-up of GHGs in the atmosphere is very likely the 

cause of most of the observed global warming over the past 50 years. A detailed 

explanation of climate change and its impact on health, society, and the environment is 

provided in EPA’s “Technical Support Document for Endangerment and Cause or 

Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act,” 

available at http://epa.gov/climatechange/Downloads/endangerment/Endangerment_TSD.pdf.

EPA has jurisdiction over the GHG portion of PSD permits issued to major stationary 
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sources of air pollution in Florida. The State of Florida has jurisdiction over PSD permitting 

for all NSR-regulated air pollutants other than GHGs. FDEP issued a permit for non-GHG 

emissions for the facility in May 2012. On a net basis, emissions from the facility will 

decrease for all pollutants except CO, VOCs, and GHGs. GHG emissions are projected to 

have a net increase of up to 1.9 million tons per year of GHG emissions on a carbon 

dioxide-equivalent (CO2e) basis.

3. Comment: The Port Everglades FPL Plant will raise emissions not decrease emissions. I 

am truly concerned with the Draft Permit as presented is missing substance, depth, information, 

and quite frankly it should be called “Permit Light”. 

EPA Response: EPA has followed existing regulations and guidance for the issuance of 

PSD permits for GHGs. As described above, on a net basis, emissions from the facility will 

decrease for all pollutants except CO, VOCs, and GHGs. EPA’s guidance for permitting

GHGs can be found here: http://www.epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf .

4. Comment: Why did we not hear of this additional permitting action by EPA until the 

published notice? In other words, why was there no effort to inform and conduct outreach to 

the population of South Florida on this entirely different kind of permit. This did not afford an 

opportunity for the public and myself to become informed of the issues so we can understand 

and comment on this very complicated permit.

EPA Response: EPA followed existing regulations pertaining to the public notice process 

for PSD permits (40 CFR 124.10). The purpose of the 30-day public comment period is to 

inform the public of EPA’s intent to issue a permit, and to allow the public to provide input 

in the form of written comments. Additionally, on January 27, 2012, EPA published on its 

website that it had received the PSD application. This website is updated periodically 

throughout the permitting process.

5. Comment: Where is the public outreach, education and information that EPA would have 

everyone believe it conducts? Where is the public input? I am amazed that there is absolutely 

no public engagement or education other than a notice in the Sun Sentinel next to garage sale 

ads.

EPA Response: See response to Comment 4 and the Introduction section of this 

document.

6. Comment: What is the meaning of 4 million tons greenhouse gases from a coastal facility 

presumably subject to the effects of rising ocean levels? For how many years can it operate 

with ever increasing greenhouse gas emissions? 

EPA Response: A detailed explanation of climate change and its impact on health, 

society, and the environment is provided in EPA’s “Technical Support Document for 

Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 

202(a) of the Clean Air Act,” available at 

http://epa.gov/climatechange/Downloads/endangerment/Endangerment_TSD.pdf. Research 

into the effects of GHGs on the environment is ongoing. The Port Everglades facility must 

be constructed and operated in accordance with the permit application and must comply 
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with the GHG emission limitations in the final permit. FPL must obtain another PSD permit 

prior to making a physical or operational change that would significantly increase GHG 

emissions beyond what is allowed by this permit.

7. Comment: Why does EPA plan to issue a permit when the National Oceanic and 

Atmospheric Administration (NOAA) Fisheries Service is currently reviewing the proposed 

project consistent with Section 7 of the Endangered Species Act? What are the endangered 

species? We should be provided an explanation of the issues and the reasons why NOAA has 

not reached a conclusion on the project.

EPA Response: In this case, Section 7 of the Endangered Species Act required EPA to 

consult with NOAA prior to its final permit action. The Endangered Species Act process 

can take a significant amount of time; thus, EPA issued the draft permit in parallel with the 

finalization of NOAA’s review. EPA is typically not able to issue a final permit until 

NOAA completes its review. NOAA completed its review of this project on September 18, 

2013, and concluded that “the action, as proposed, is likely to adversely affect loggerhead, 

green, and hawksbill sea turtles, but it is not likely to jeopardize their continued existence.” 

NOAA’s Biological Opinion, which provides NOAA’s analysis of the project’s potential 

impacts on endangered species, is available as part of the administrative record on

www.regulations.gov. Furthermore, the final permit will include the “Terms and 

Conditions” as required by NOAA and specified in Section 9.4 of the Biological Opinion to 

ensure that the applicant will monitor and report all interactions with any protected species. 

(see Condition IX.A and Section XI of the final permit). 

8. Comment: Where are the studies exclusive to the unique ecosystem of the State of Florida?

Where are the studies involving weather patterns unique to Florida?

EPA Response: Due to their long atmospheric retention times, among other factors, 

GHGs are considered a global pollutant, as opposed to a local pollutant. Furthermore, 

quantifying the exact impacts attributable to a specific GHG source obtaining permit in 

specific places and points would not be possible with current climate change modeling. See

GHG Permitting Guidance at 48. As such, local considerations are not examined in this 

permit. The most practical way to address concerns with impacts to specific areas from 

GHG emission is by reducing GHG emission to the maximum extent. Additional research 

into the effect of GHG emissions on climate change and impacts of climate change at 

specific locations is ongoing.

Comments Submitted by Sierra Club

9. Comment: The Region Must Establish the GHG BACT Limit Based on the Most-Efficient, 

Lowest Polluting Turbine Design Technology.

The draft permit failed to set GHG emission limits based on the most efficient, and therefore 

lowest emitting, combined cycle turbine design. The SOB considers two turbine designs: (1) 

the Mitsubishi Power Systems (MPS) “J” and (2) the Siemens “H” turbine design. However, 

the calculated emissions of these two designs are not equal in terms of GHG emissions. Tables 

5-1 and 5-2 show that the MPS design would emit approximately 351,000 tons of CO2e per 

year more than the Siemens model. That is an increase of 8.6 percent in GHG emissions. 
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The SOB states that the heat rates and energy efficiencies for these units “were evaluated and 

shown to be more efficient compared to other operating power generating facilities of similar 

size and class.” (SOB at p.11) While it appears that the designs evaluated by FPL are some of 

the most energy efficient turbine/HRSG options available, Region 4 must still select the BACT 

limit based on the most efficient design, unless the applicant demonstrates a sufficient sitespecific basis to reject a particular technology. Here, the applicant cannot make this claim 

because there is no evidence that either the MPS or the Siemens designs would be infeasible at 

the Port Everglades site. To the contrary, FPL indicates that it is able to choose between the two 

turbine technologies. The PSD permit must require the Port Everglades Project to meet a GHG 

emission rate that is achievable by the most efficient unit, which in this case is the Siemens H 

design that would emit 8.6 percent less GHG pollution than the MPS design. 

Clean Air Act § 165(a)(4) requires the Region to select the Best Available Control Technology 

(BACT) as the basis for the emissions limit, which is defined as “an emissions limitation ... 

based on the maximum degree of reduction for each pollutant subject to regulation under the 

Act...” 42 USC 7479(3); 40 CFR 52.21(b)(12). Reducing GHG emissions is directly related to 

minimizing the quantity of fuel required to make electricity. In this case, the proposed annual 

CO2e emissions of the Siemens design are 8.6 percent lower than the MPS design, a difference 

of 351,573 tons/yr CO2e. This difference in emissions is important, particularly because the 

SOB concludes that energy efficiency options are the preferred option for BACT as opposed to 

an add-on technology. 

The PSD provisions do not allow the permitting authority to select a higher emitting technology 

based on the applicant’s potential preference for a different turbine/HRSG design. The BACT 

requirement is defined as “the maximum degree of reduction for each pollutant.” 42 USC 

7479(3). FPL does not suggest that the Siemens design is infeasible or inconsistent with the 

purpose of the project. Therefore, the top-down BACT analysis requires the Region to select 

the lowest emitting technology as the basis for setting the BACT emission limit. 

Energy efficiency is a critical component of the BACT analysis, particularly for GHGs. EPA’s 

PSD and Title V Permitting Guidance for Greenhouse Gases is clear on this point: “Use of 

inherently lower-emitting technologies, including energy efficiency measures, represents an 

opportunity for GHG reductions in these BACT reviews.” The energy efficiency of a 

technology is fundamental to the BACT determination. “Initially, in many instances energy 

efficient measures may serve as the foundation for a BACT analysis for GHGs, with add-on 

pollution control technology and other strategies added as they become more available.” In this 

case, in addition to considering add-on technologies such as carbon capture and sequestration 

(CCS), the Region must first establish the BACT limit foundation by setting the limit based on 

the most energy efficient technology design. “When a permit applicant proposes to construct a 

facility using a less efficient boiler design...a BACT analysis for this source should include 

more efficient options.”

There is no dispute that different turbine/HRSG designs result in different annual GHG 

emissions. The Region does not, however, acknowledge the importance of the 8.6 percent 

difference in annual GHG emissions of the turbine/HRSG designs analyzed in the SOB, 

concluding instead that the two designs “were evaluated and shown to be more efficient 

compared to other operating power generating facilities of similar size and class.” (SOB at 
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p.11) Ignoring these recognizable and achievable energy efficiency gains evident between the 

two turbine/HRSG designs considered in the draft permit is contrary to the Region’s PSD and 

Title V Permitting Guidance for Greenhouse Gases, which expressly addresses an example of 

energy efficiency at a coal plant: 

In general, a more energy efficient technology burns less fuel than a less energy efficient 

technology on a per unit of output basis. For example, coal-fired boilers operating at 

supercritical steam conditions consume approximately 5 percent less fuel per megawatt 

hour produced than boilers operating at subcritical steam conditions.

The EPA guidance makes clear that energy efficiency must be considered in the BACT 

analysis. There is no basis for determining that “some of the most efficient” designs all 

constitute BACT. The NSR Manual provides: “The reviewing authority...specifies an 

emissions limitation for the source that reflects the maximum degree of reduction 

achievable...” (NSR Manual, p.B.2 (emphasis added)). Without a showing that the most 

efficient design is either technically infeasible or that it should be eliminated due to 

disproportionate site-specific energy, economic or environmental impacts, the Region must set 

the GHG BACT emission rate limit based on the most efficient turbine design. 

It is irrelevant for purposes of the BACT analysis that the applicant may wish to make a final 

selection of the turbine design based on a choice among multiple options. BACT is required by 

law and is not an afterthought that can be subordinated to other considerations. (NSR Manual at 

p.B.31.) The Region must set the GHG emission limit based on the most energy efficient 

turbine design. Turbine vendors that can meet that limit are free to compete for FPL’s business. 

This feature of the BACT program has been remarkably successful in encouraging 

development of more effective pollution controls for over 40 years.

EPA Response: We disagree with the commenter’s assertion that the different models of 

comparably efficient combustion turbines are different technologies for purposes of the

BACT analysis. The PSD provisions do not take away an applicant’s ability to consider 

factors independent of air quality permitting, like turbine capacity, in its selection among 

equipment vendors so long as the PSD requirements have been addressed. The permit 

application states that the purpose of the FPL Port Everglades Next Generation Clean 

Energy Center Project is to replace 1200 MW of 1960s era existing generating capacity 

with 1250 MW of highly efficient generating capacity using the latest combined cycle 

technology in a “3-on-1” unit configuration (see page 1-1 of the application and application 

cover letter to EPA dated January 23, 2012). EPA’s BACT analysis treats current combined 

cycle combustion technology with efficient turbine design, and without regard to particular 

turbine models or capacities, to be an “available control option.” “Combined cycle 

combustion turbines” are described as a collective option in the PSD and Title V Permitting 

Guidance for Greenhouse Gases. (see GHG Guidance at 29). Both of the turbine models 

discussed in the application apply the most efficient turbine design technology available to 

achieve the desired capacity and configuration of the facility. For additional information on 

EPA’s Combustion Turbine BACT analysis, see EPA’s response to Comment 15 below. 

EPA did consider the energy efficiency of the combustion turbines in the top-down BACT 

analysis. Due to uncertainties with future costs and details of bidding and procurement, FPL 

found it necessary to propose two alternative combustion turbine models, Mitsubishi Power 
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Systems (MPS) “J” and Siemens “H.” EPA concluded that the two proposed combustion 

turbine designs are comparable in efficiency. Specifically, according to the information 

supplied by the Applicant in the response to EPA dated May 8, 2012, which turbine model 

is more efficient depends on the specific load level and the fuel being used at the time. For 

instance, the MPS “J” turbine operating at 100% load on natural gas has a 54.0% net 

efficiency and a 55.6% gross efficiency, while under the same conditions the Siemens “H” 

turbine has net and gross efficiencies of 52.9% and 54.6%, respectively. Under this 

scenario, the MPS “J” turbine is 1.1% more efficient. However, in the more likely scenario 

of 75-80% load and natural gas-firing, the MPS “J” (75% load) and Siemens H (80% load) 

turbines have the same 51.9% net efficiency rating. Furthermore, under the scenario of 

100% load and firing ULSD fuel oil, the MPS “J” turbine has a 47.9% net efficiency while 

the Siemens “H” has a 50.8% net efficiency. In this case, the Siemens “H” turbine is 2.9% 

more efficient, however, given the limit of ULSD fuel oil use, this scenario will occur much 

less frequently. Thus, given the similarity in efficiencies and the uncertainty of operating 

scenarios, the same GHG BACT emissions limits would have applied regardless of the 

combustion turbine design chosen. 

When there are multiple control technology alternatives under consideration that result in 

essentially equivalent emissions, EPA has recommended that permit applicants exercise 

some judgment in deciding which alternatives to examine in detail in the subsequent steps 

of the top-down BACT process. In re: Prairie State Generating Station, 13 E.A.D. 1, 25 

(EAB 2006) (quoting the NSR Workshop Manual at B.21-B.22). While this observation has 

been made in the context of determining whether it is necessary to examine technologies 

with equivalent performance beyond Step 2 of the top-down BACT process, a similar logic 

can be extended to the situation presented here where there is more than one model within a 

category of control technology and each model has a comparable control efficiency. 

Sierra Club is correct that the annual ton per year (TPY) emissions for the two models 

differ by 8.6%. This is because the MPS “J” model turbine has a greater generating capacity

than the Siemens “H” model turbine. This capacity difference is not a factor in the BACT 

determination because the BACT limit applies on an output-based per megawatt (net 

generation) basis and is linked to the efficiency of the turbines, not the capacities.

10. Comment: The Region Should Clarify the Type of Fuel Used as Backup Fuel Oil.

Sierra Club supports the region’s determination to split the GHG BACT limit for operations on 

natural gas and for fuel oil; however, the Region must clarify they type of fuel to be used as 

backup “fuel oil.” FPL proposes to operate the facility’s combined-cycle turbines on natural 

gas, with up to 1000 hours per year on fuel oil. We note that the draft permit is inconsistent 

with respect to the fuel allowed for the 1000 hours of operation, variously describing it as "fuel 

oil" (Condition IX.C.1) and Ultra Low Sulfur Diesel (Condition IX.C.2). It appears that the 

applicant intended ULSD to refer to “light oil,” but the draft permit and SOB do not include a 

consistent definition and use for ULSD. BACT requires an evaluation of lower emitting fuel 

alternatives; therefore, the Region should conduct an analysis of fuel oil alternatives and 

include a permit condition that requires the cleanest burning fuel available. Our comments that 

follow refer to “fuel oil,” regardless of the actual language in the Statement of Basis, which 

variously refers to this fuel as "fuel oil," "ULSD", and "ULSD fuel oil." 
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FPL had proposed a greenhouse gas (GHG) best available control technology (BACT) limit 

that averaged the CO2 emissions of 7,760 hours of operation with natural gas and 1000 hours 

with fuel oil. Region 4 properly rejected this approach and instead set two separate GHG 

BACT limits for each fuel type. Splitting the BACT limit based on fuel type is appropriate. 

Operating the combustion turbines on fuel oil is far less efficient than operating with natural 

gas. Setting a blended limit would have allowed FPL to operate the plant at a less efficient rate 

than the combined-cycle turbines are capable of meeting. 

Fuel oil operation at the Port Everglades Project should only be used as a backup in cases of 

emergency, and therefore a less protective GHG BACT limit should only apply during those 

emergencies. Even if the Port Everglades facility is permitted to operate up to 1000 hours on 

backup fuel, which as discussed in more detail below is far too high, that does not mean that the 

facility will operate on 1000 hours of fuel oil each year. Under normal operating conditions, the 

facility should run on natural gas. It is therefore appropriate to require the facility to meet the 

best achievable GHG limit that the combined-cycle natural gas turbines can achieve while those 

units are operating under non-emergency conditions on natural gas.

EPA Response: EPA appreciates the commenter’s support to propose two separate 

BACT limits and agrees that Ultra Low Sulfur Diesel (ULSD) fuel oil shall be used for all 

backup fuel oil firing processes. Usage of the term “fuel oil” shall be revised to the term 

“ULSD” throughout the permit. See response to Comments 11 and 13 regarding use of 

ULSD for backup.

11. Comment: The BACT Requirement to Consider Cleaner Fuels Precludes the Use of Fuel 

Oil Absent Stringent Restrictions.

Draft permit Condition IX.C(2) would allow the Port Everglades project to operate using fuel 

oil for up to 1000 hours on a 12-month rolling total. There are no restrictions on what 

conditions must be present for FPL to operate the facility on fuel oil, and there is no definition 

in the draft permit for what constitutes an “emergency” that would require the use of backup 

fuel oil. This permit condition therefore substantially increases the potential GHG emissions at 

the facility. 

The SOB states that FPL intends to operate on fuel oil under various conditions, including “the 

need for electricity at a reasonable cost, and whether [fuel oil] is the most cost-effective 

alternative available.” (SOB p.12-13) In other words, FPL intends to operate the Port 

Everglades facility on fuel oil whenever it is cheaper to do so. This proposed operation of the 

facility does not comply with the Clean Air Act’s requirement that facilities operate with the 

best available control technologies. The SOB clearly acknowledges that the use of natural gas 

as a fuel source is an inherently lower emitting practice than the use of fuel oil. (SOB p.12) The 

draft permit’s GHG limit is 42 percent higher for fuel oil than for natural gas, and the fuel oil 

limit of 1,176 lb CO2e/MWh does not even come close to meeting the proposed new source 

performance standard of 1000 lb/MWh for combined-cycle units. In short, fuel oil is an 

outdated and dirty technology that does not meet the requirements that the facility comply with 

BACT limits.

Despite the obviously higher pollution from fuel oil use, the Region does not provide any 

restrictions on the use of fuel oil, other than an arbitrary cap of 1000 hours on a 12-month 
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rolling average. This means that the facility can operate on fuel oil up to 1000 hours annually 

regardless of whether there is any emergency, any limit to natural gas supply, or any risk of 

electric system reliability. FPL can simply switch to fuel oil whenever it decides that fuel oil is 

cheaper. The top-down BACT analysis does not allow this condition. The Region must set 

limits based on the technologies that are feasible. In this case, the use of natural gas fuel is 

clearly feasible because it is the primary purpose of the plant. The Region rejects “100% use” 

of natural gas “[b]ased on the need for reliability and the risk associated with Florida’s limited 

pipeline system.” (SOB p.13) However, the draft permit’s conditions are not narrowly tailored 

to alleviate the concerns of reliability and natural gas supply disruption. Even if it were 

reasonable to allow the use of fuel oil in an emergency, such as a pipeline disruption caused by 

a hurricane, the draft permit’s allowance of up to 1000 hours every year is completely arbitrary 

and would allow FPL to operate on fuel oil even absent any “reliability and risk” concerns. 

The Region must revise the permit condition allowing the use of fuel oil to state that fuel oil 

may only be used during times of natural gas supply disruption due to emergency, and in no 

case may the use of fuel oil exceed 100 hours annually. The Region should also include a 

definition of “emergency” conditions that warrant use of backup fuel oil, and that definition 

should specify that high natural gas prices are not by themselves an emergency. Fuel oil should 

only be used in cases of true emergency that disrupts the ability to deliver natural gas to the 

Port Everglades facility. BACT requires the best available technology, and in this case the 

facility must operate on natural gas fuel unless it is infeasible to do so.

EPA Response: The commenter is correct in noting that the permit does not restrict the 

use of ULSD to only emergency situations. Consequently, EPA did not define the term 

“emergency” for the purposes of using ULSD in the turbines. Rather, the 1000-hour limit is 

based on information provided in the application as well as on additional information 

submitted by the applicant by email on November 16, 2012. See email and attachment dated 

November 16, 2012, in the administrative record. In this email, the applicant provided 

additional information supporting the basis for requesting an annual 1,000 hours of ULSD 

operation per turbine. As explained by the applicant in the November 16, 2012 email, the 

Florida Public Service Commission (FPSC) took into account several factors when it issued 

the Final Order Granting Determination of Need on April 9, 2012 (see page 2 of FPSC 

Final Order 040912, included in the final permit Docket). These issues included “...the 

need for electric system reliability and integrity, the need for adequate electricity at a 

reasonable cost, the need for fuel diversity and supply reliability...” In determining the 

proposed 1,000 hours of ULSD, the applicant also considered the amount of back-up 

capacity that is being replaced with this project and the effects that would have on the fuel 

diversity and reliability of the system. Finally, the applicant provided historical information 

on recent hurricanes that supports the requested amount of backup fuel is justified. On the 

contrary, the commenter has not provided any support for the suggested limit of 100 hours 

per year per of ULSD nor any documentation for why this limit is more appropriate for this 

project than that proposed by the applicant. EPA believes that the applicant has provided 

adequate justification for the proposed use of 1,000 hours of ULSD per turbine annually. 

Finally, the commenter states that the proposed BACT limit for ULSD does not meet the 

previously proposed NSPS (TTTT). It should be noted that EPA withdrew this proposed 

NSPS and on September 20, 2013, proposed new GHG emission standards for Power 

Plants. In the new standard, as with the previous proposal, EPA does not distinguish 
13

between fuel type (natural gas or ULSD) from combustion turbines, but set a limit on the 

overall GHG emissions from an affected unit (i.e., 1,100 lb CO2/MWh). The definition of 

BACT in PSD rules at 40 CFR 52.21(b)(12) states that “in no event shall application of best 

available control technology result in emissions of any pollutant which would exceed the 

emissions allowed by any applicable standard under 40 CFR parts 60 and 61.” Although 

this facility may be within the source category covered by the proposed NSPS, the proposed 

NSPS emission limits are not a controlling floor for BACT purposes since the proposed 

NSPS is not a final action and the proposed standard may change. However, the NSPS is an 

independent requirement that will apply to any source subject to the NSPS that commences 

construction after the date the NSPS is proposed (unless that source is covered by a 

transitional source exemption adopted in the NSPS). Thus, this facility may ultimately be 

subject to, and need to comply with, the NSPS after it is finalized. See EPA, PSD and Title 

V Permitting Guidance for Greenhouse Gases (March 2011) at 25. 

12. Comment: Use of Duct Firing is Unclear.

FPL’s application states that the Project will not have duct firing. (Application, p.4-13 (“these 

CTs will not have duct firing””)) However, Table 5-1 in the SOB indicates that the MPS 

turbines design will have “CTs/HRSGs with Duct Burners.” (SOB p.7) It is possible, though 

unclear, that the addition of duct burners in the MPS unit accounts for the 8.6 percent higher 

annual CO2e emissions. As FPL noted in its application, duct firing is less efficient than 

combined-cycle operations and therefore produces CO2e emissions at a higher rate. The Region 

should clarify that the GHG emission rate was not calculated based on duct firing and should 

amend Table 5-1 to eliminate the reference to duct firing if indeed duct firing was not included. 

If, on the other hand, the GHG BACT limit was determined based on an assumption that duct 

burners would be used with the MPS turbine design, then the Region should reevaluate the 

BACT analysis to consider other, cleaner alternatives. The top-down BACT analysis should 

look at cleaner production processes for achieving the additional on-peak energy that the duct 

burners would provide. Alternatives to duct burners could include battery storage, solar hybrid 

configuration (or a combination battery and solar hybrid), a small combustion turbine, and 

using the auxiliary boiler for supplemental steam. Sierra Club notes that the heat rate from duct 

burning is approximately the same, or worse, than the efficiency of new internal combustion 

engine generators, which is to say that it is very inefficient as a source of peaking generation 

capability. Addressing the least efficient part of a proposed plant—the duct burning peak 

topping generation—can significantly increase a plant’s overall efficiency without redefining 

the project. There are numerous alternatives for short-term, peak power generation at the scale 

proposed for duct burning at the Project that would achieve significant reductions in not only 

GHGs, but in other pollutants. The Region has not addressed any of these alternatives in the 

draft permit and, in fact, has stated that duct burners will not be used even though they are 

shown in the emission tables.

EPA Response: Table 5-1 in the Preliminary Determination indicates the use of duct 

burners for the combustion turbines. This is a typographical error. Duct burners will not be 

used and are not authorized in the final permit.

13. Comment: The Region’s BACT Analysis for the Compressor Station is Inadequate.
14

The proposed compressor station at the Port Everglades facility would be the second largest 

contributor to GHGs with 55,313 tpy permitted by the draft permit. However, the SOB contains 

almost no analysis of the compressor station’s emissions, and the only limitation on the 

operation of the compressors is that “only 2 of 3 compressors shall operate at a time.” (SOB 

p.15) Even this operational limit is eliminated by draft permit Condition IX.E(5) in cases of an 

undefined “emergency.” 

The BACT analysis for the compressor station is completely lacking and does not meet the 

requirements of a top-down BACT analysis. The Region’s BACT analysis did not consider the 

use of more efficient turbines to drive the compressors, and the analysis ignored major potential 

sources of emissions from the compressor station, including fugitive emissions of methane 

from compressor seals, valves and connectors, and blowdown emissions. The draft permit also 

omits any compliance reporting. The Region only requires record keeping for the compressor 

station, but there are no monitoring or compliance requirements applicable to the compressor 

station that would ensure that the annual limit of 55,313 tpy is not exceeded. The compressor 

station must be included in a rigorous BACT analysis with a clear, measurable, and enforceable 

compliance requirement.

EPA Response: While the commenter is correct that the Natural Gas Compressors are the 

second highest contributor of GHG emissions in this project (at 55,313 TPY of CO2e), it 

should also be noted that the compressor emissions only constitute 1.2% of the total GHG 

emissions of this project. Furthermore, the commenter is incorrect in the statement that the 

only limit on the compressors is that “only 2 of 3 compressors shall operate at a time.”

Condition IX.E.1 of the permit limits the emissions of the gas compressors to 55,313 TPY 

of CO2e, which is a limit that applies at ALL times. This emission limit is based on the 

operation of 2 compressors, each operating a maximum of 8,760 hours per year, as 

described in the permit application (Table A-18). Therefore, even though the permit 

provides the applicant flexibility to operate more than 2 compressors during an emergency 

(Condition IX.E.5) the applicant is still bound by the annual BACT emission limit in 

Condition IX.E.1 as well as the recordkeeping requirements of IX.E.5.

A top-down BACT analysis for the natural gas compressor station was conducted, as 

indicated in Section 6.2 of the Preliminary Determination and included in Section 4.3.2 of 

the permit application (see pages 4-17 to 4-21). As stated on pages 2-5 and 4-19 of the 

GHG PSD application, and in the May 8, 2012 Response to Comments (RTC) letter, if 

installed onsite the compressors will consist of a Solar Centaur 50 combined 

turbine/compressor configuration or equivalent and will have an energy efficiency of 

29.3%. Additionally, the applicant points out that the primary design criterion for the 

compressor is to provide the necessary compression and the Solar Centaur 50 provides the 

necessary power with lower emissions than the equivalent internal combustion engine (see

page 8 of May 8, 2012 RTC letter). Furthermore, it will be fueled by natural gas, which is 

much lower in GHG emissions than fuel oil. The commenter has not provided any 

additional information regarding the existence of a more efficient turbine which would meet 

the needs of the applicant’s proposed use of this emissions unit. Any small increase in 

efficiency gained by using a different (and more costly) model of natural gas turbine would 

likely not be cost effective given the relatively small amount of GHG emissions from this 

unit. EPA concludes that the BACT analysis performed and the supplemental information 

provided by the applicant in the May 8, 2012, RTC letter is adequate considering the 
15

extremely low volume of GHG emissions from these emission units. Similarly, the 

commenter has also failed to show that a BACT analysis should have taken account of 

additional sources of emissions from the compressor station or included compliance 

requirements. The commenter does not challenge the finding that compressor emissions 

constitute 1.2 % of the total GHG emissions of the project and does not show that the 

purported failure to consider additional sources of emissions from the compressor or to 

impose more detailed compliance requirements makes the permit inadequate or offer any 

specific suggestions for remedying the purported problems. 

Finally, the commenter raised the issue that the permit did not define “emergency” as 

referenced in Condition IX.E.5. The term “emergency” can generally be thought to 

encompass natural disasters, catastrophic equipment failures, or otherwise unforeseen or 

unavoidable events that would temporarily impact the ability of the facility to operate. EPA 

will use its discretion on a case-by-case basis to determine whether a particular event 

constitutes an emergency with respect to the compressor station.

14. Comment: The Draft Permit Does Not Set Any Method for Determining Compliance with 

Auxiliary Equipment Emissions Limits.

The draft permit includes annual GHG emission limits for the auxiliary equipment (auxiliary 

boiler, emergency generators, gas compressors, fire pump engine, circuit breakers, and 

temporary construction boilers). (Draft Permit, Condition IX.E(1)) However, the draft permit 

does not establish any methods to determine compliance with the annual emission limits for 

auxiliary equipment. The draft permit only requires FPL to monitor fuel flows for the auxiliary 

boilers, emergency generators, and fire pump engines, but the monitoring of fuel flows does not 

by itself ensure that FPL is operating the equipment efficiently or in compliance with the 

appropriate annual limit. There is no requirement or methodology included in the draft permit’s 

conditions that require calculation of annual GHG emissions based on emission factors 

determined from periodic stack tests and fuel usage or time of operation. The Region should 

revise the permit to ensure that there are clear, enforceable compliance methods to determine 

that the Port Everglades Project will meet the annual GHG emission limits for auxiliary 

equipment.

EPA Response: EPA agrees that the permit should be revised to ensure that there are 

clear, enforceable compliance methods to determine that the annual GHG emissions limits 

for the auxiliary equipment will be met. The final permit now includes Condition IX.H.3 to 

address this concern. 

15. Comment: The Region Improperly Ignored Other BACT Limits.

FPL stated in the application that the Project would have a heat rate 10 percent lower than 

average existing combined-cycle plants based on 2009 EIA data. (Application, p.4-15) The 

SOB similarly stated that the units “were evaluated and shown to be more efficient compared to 

other operating power generating facilities of similar size and class.” (SOB at p.11) This 

comparison to the average of existing units is not determinative for a BACT limit. The Region 

must consider the best achievable emissions limits, not an average of existing units. The Region 

must consider an evaluation of recently permitted and constructed units. For example, the 

Palmdale Hybrid Power Project has a permitted GHG BACT limit of 774 lb CO2/MWh. If 
16

Palmdale is able to achieve 774 lb CO2/MWh, then the Region must consider those control 

technologies and the associated emission rates as part of the BACT analysis for the Port 

Everglades Project.

EPA Response: While the applicant provided EPA with information comparing the 

efficiency of the PEEC to existing combined cycle plants, EPA also considered recently 

permitted and constructed units as part of the establishment of the BACT for the permit. 

The permit limit of 774 lb CO2/MWh referenced by the commenter (Palmdale Hybrid 

Power Project) is a source-wide net output based limit. This limit was based on operation at 

100% load for a 563 MW (net) power plant, which includes an integrated 50 MW solar 

power facility. The Palmdale permittee can include up to 50 MW of solar generated 

electricity when showing compliance with the 774 lb CO2/MWh source-wide emission 

limit. The Port Everglades Project is for 1250 MW of power and will rely primarily on 

natural gas with ULSD fuel oil as backup and will not have the benefit of solar generated 

electricity to show compliance with the BACT limits. Furthermore, the natural gas fired 

BACT limit of 830 lb CO2e/MWh proposed for Port Everglades was based on operation 

over a range of load levels (averaging 75%) as compared to 100% load, which was used to 

set Palmdale’s limit. For these reasons, the source-wide BACT limit in Palmdale is not an 

appropriate comparison to the unit-specific BACT limits in this permit. Furthermore, in a 

search of the RACT/BACT/LAER Clearinghouse database as well as other known PSD 

permits which contain BACT limits for GHG emissions for large (~1250 MW) baseload 

(combined cycle) power plants, EPA was unable to identify natural gas GHG output-based 

(lb/MWh) BACT emission limits that were lower than those being proposed for Port 

Everglades. Finally, in a search for any other model combustion turbine of comparable size, 

EPA was only able to identify the General Electric “H” system turbine as comparable to the 

MPS “J” and Siemens “H” turbines being considered by the applicant for this project. All 3 

model turbines are of similar efficiencies and represent the latest in combustion technology 

for this size turbine. (see Power Engineering International article titled “Efficiency vs. 

Flexibility: Advances in gas turbine technology” which is included in the administrative 

record). See EPA’s response to Comment 9 above for a detailed discussion of the 

efficiencies of the turbines being considered for this project. EPA believes the BACT 

analysis is adequate to demonstrate the applicant is proposing the use of the most efficient 

turbines available in its class (and size) and the commenter has not provided any 

information regarding a comparable turbine with greater efficiency beyond those being 

considered for this project. 

16. Comment: Startup Periods are Too Long.

The draft permit Condition IX.D allows up to four hours for cold startup and 2 hours for warm 

and hot startup in any 24 hours period. This period of startup and shutdown is important 

because the GHG BACT limits in Condition IX.C do not apply to startup and shutdown. This 

exemption means that the facility’s combustion turbines can emit more than 832 lb CO2e/MWh 

for several hours each day. This exception is excessive and unnecessary. Further, there is no 

limit on the number of these startup and shutdowns. 

New turbine design technology allows for combined-cycle turbines to startup very quickly –

within 30 minutes for warm startups and 90 minutes for cold startups. For example, the 

proposed Oakley Generating Station in California is designed to be able to start up and dispatch 
17

quickly with GE’s Rapid Response package.6 The Rapid Response package allows the plant to 

start up from warm or hot conditions in less than 30 minutes. The Rapid Response package 

achieves this fast performance by initially bypassing the steam turbine when the gas turbines 

are started up. In a conventional combined-cycle system, the gas turbine needs to be held at low 

load for a period of time while the HRSG is warmed up and steam is gradually fed into the 

steam turbine and the steam turbine is brought up to operating temperature. The steam turbine 

needs to be brought up to operating temperature slowly in order to minimize thermal stresses on 

the equipment and to maintain the necessary clearances between the rotating and stationary 

components of the turbine. This delay necessitated by having to slowly warm up the HRSG and 

steam turbine means that the gas turbine cannot increase load as rapidly as a simple-cycle gas 

turbine to quickly provide power to the grid. It also causes increased emissions, including CO2, 

because the combustion turbine needs to be held at low load – where it is not as efficient –

while the HRSG and steam turbine are warmed up. The GE Rapid Response system initially 

bypasses the steam turbine when the combustion turbines are started, allowing them to ramp up 

quickly and begin providing power to the grid. The steam turbine can then be warmed up 

slowly without requiring the combustion turbines to be held at low load (except for a short time 

for cold startups), through the controlled admission of steam from the HRSGs into the steam 

turbine. The Rapid Response package therefore allows the facility to start up and begin 

providing power more quickly than a conventional system, which will enhance operational 

flexibility and reduce emissions associated with startups. 

The Region must consider whether a fast-start turbine design available from GE or similar faststart designs from other turbine manufacturers could be used at the Port Everglades facility to 

reduce startup times and thereby reduce overall GHG emissions. 

In addition to setting excessively long startup and shutdown periods, the Region also fails to 

require the facility to meet any GHG emission limit during startup, shutdown and maintenance 

(SSM). The Region cannot summarily exempt Port Everglades from GHG BACT limits during 

SSM. “[The permitting agency] must make an on-the-record determination as to whether 

compliance with existing permit limitations is infeasible during startup and shutdown, and, if 

so, what design, control, methodological or other changes are appropriate for inclusion in the 

permit to minimize the excess emissions during these periods.” Rockgen Energy Center, 8 

E.A.D. 536, 544 (EAB 1999). There is no discussion in the SOB about any impediments to 

meeting the GHG BACT limit during SSM. The blanket exemption from meeting any GHG 

BACT limit during SSM therefore fails to comply with BACT requirements. EPA must revise 

the draft permit to ensure that emissions are minimized to the maximum extent achievable 

during periods of SSM.

EPA Response: The exclusionary statement in Condition C.1 of the draft permit, “Except 

as noted below under Condition IX.D,” was inadvertently included in the draft permit and 

will not be included in the final permit. The BACT limits in condition IX.C.1 are applicable 

at all times, including startup/shutdown/malfunction periods, therefore, it is not necessary to 

limit the length of startup/shutdown periods for GHG emissions. 

17. Comment: BACT Analysis for SF6 Emissions from Compressor Station.

Sulfur hexafluoride (SF6) is an extremely potent greenhouse gas. The SOB includes a BACT 

analysis for SF6 for circuit breakers, which are designed to be closed systems but may leak 
18

SF6. The Region determined that the BACT limit for SF6 for the circuit breakers is 4.5 tpy 

CO2e based on the use of leak detection and periodic inspection and maintenance practices. 

However, the draft permit and SOB do not address the potential for SF6 emissions from the 

compressor station. SF6 is commonly used for leak detection in natural gas pipelines as a tracer 

gas. The application does not address whether SF6 will be used for leak detection in the natural 

gas pipeline and therefore does not consider whether the compressor station will result in SF6 

emissions. The Region should clarify with FPL whether SF6 will be used for leak detection at 

the compressor station, and if so, the Region must include an SF6 BACT analysis for the 

compressor station in addition to the circuit breakers. If FPL asserts it is not used, the permit 

should be revised to include a condition forbidding its use.

EPA Response: FPL has confirmed that SF6 will not be used as a tracer gas in the natural 

gas pipelines or compressor station.

Comments Submitted by Florida Power & Light

18. Comment:

C. Combustion Turbine (CT) Emission Limits

1. Except as noted below under Conditions IX.D and J, on and after the date of initial 

startup, Permittee shall not discharge or cause the discharge of emissions from the CT 

Unit into the atmosphere in excess of the following:

• The shakedown condition should be cited in this condition.

.

Emission Limit (per CT) 

(natural gas firing)

Emission Limit (per CT) 

(fuel oil burning)

GHG Limit (as CO2e) 832 lb CO2e/MWh net

output (12-month rolling

average)

877 lb CO2e/MWh net 

output (12-month rolling 

average)

1,176 lb CO2e/MWh net

output (12-month rolling

average)

o FPL request that EPA consider the proposed as the BACT limit for PEEC that 

as described in the application includes all operating conditions such as 

startups, shutdowns, fuel switches, 2 and 1 CT operation with the steam turbine 

operating at lower less efficient loads, low load operation on 1, 2 or 3 CTs, dual 

fuel operation (oil on one CT and gas on two CTs), malfunctions of the CTs or 

steam turbine, CT performance deterioration from new and clean, and unit 

environmental testing. The BACT analysis included information on BACT 

limits for two gas-only fired combined cycle projects that were 918 and 950 lb 

CO2e/MW(net) for permits issue by EPA Regions 6 and 9, respectively. Indeed, 
19

since the PEEC GHG PSD Application has been submitted several other GHG

PSD permits have been issued for similar combined cycle projects that have 

BACT limits much higher than those proposed for PEEC. This included 

Calpine’s Deer Park Energy Center (PSD-TX-979-GHG) and Calpine Channel 

Energy Center (LLC)(PSD-TX-955-GHG) with limits of 920 lb CO2e/MW(net) 

for each project. Clearly, even including oil firing as part of the 12-month 

rolling average, establishes an appropriate BACT emission limit for this 

Project. Moreover, the proposed emission limit for USLD oil cannot be met as 

this fuel will likely be used in a much different fashion in any 12-month rolling 

period than the primary fuel, natural gas. The emissions provided in the 

application and additional information was based on full load at 75 degree F 

turbine inlet. If oil is used in the summer months the turbine inlet temperature 

will likely be much higher thereby reducing the heat rate. The amount of time 

for startup and shutdown using oil will be relatively high compared to the 

amount of operation especially when only testing is performed as testing is 

conducted for short durations. The 1,176 lb C2e/MWh as an individual limit 

cannot be achieved for USLD oil for the reasons cited above.

EPA Response: In response to the comments above, we agree that shakedown will not be 

included in BACT limit and the shakedown condition with be referenced in Condition IX.C.1.,

as requested. This is consistent with the concept of shakedown in 40 C.F.R. § 52.21(b)(3)(viii). 

However, due to significant differences in emissions for each fuel type, it is not appropriate to 

combine natural gas and fuel oil usage into one limit for this facility as was initially proposed 

by that applicant. The final permit will continue to contain two BACT emission limits, which 

EPA believes is the most appropriate for this project. Furthermore, while the description of how 

BACT was set on page 13 of the Preliminary Determination is correct, the proposed numerical 

natural gas and ULSD emissions limits are incorrect due to a mathematical error. The final 

BACT limits will be changed to 830 lb CO2e/MWh for natural gas and 1,248 CO2e/MWh for 

ULSD as reflected in Condition IX.C.1. This should alleviate the commenters concerns about 

not being able to meet the 1,176 lb CO2e/MWh limit on an individual basis.

2. Each The three CTs associated with PEEC CT shall not operate firing Ultra Low Sulfur 

Diesel (ULSD) more than an aggregate of 3,000 1,000 hours/year on a 12-month rolling 

total. The Permittee shall monitor and record the number of hours each CT operates on 

ULSD to be recorded monthly and totaled every month for the previous 12 months.

o This condition is requested to be the same as that in the FDEP authorization, 

that is: “Operation: The hours of operation of Unit 5 are not limited (8,760 

hours per year). ULSD fuel oil may be fired up to the fuel equivalent of 3,000 

hours aggregated over the three CTGs during any calendar year. [Application 

No. 0110036-010-AC; Rule 62-210.200(PTE), F.A.C.] This allows flexibility in 

operation and would not increase GHG emissions. In contrast, if oil is used and 

only one CT is required it will likely be the CT that operates best when oil-fired.

EPA Response: Since GHGs are a global pollutant and do not have any short-term air quality 

standards associated with the pollutant, EPA agrees that ULSD fuel oil may be fired up to 
20

3,000 hours aggregated over the three CTs during a 12-month period without any negative 

environmental impacts. EPA amended Condition IX.C.2 to allow this flexibility.

19. Comment:

D. Requirements during Combustion Turbine Startup and Shutdown

1. Startup is defined as the commencement of operation of any emissions unit which has shut

down or ceased operation for a period of time sufficient to cause temperature, pressure, 

chemical, or pollution control device imbalances, which result in excess emissions above the 

limits in Condition IX.C.

a. A cold startup means a startup when the CT has not been in operation during the

preceding 48 hours. A cold “startup of the steam turbine system” is defined as startup of

the 3-on-1 combined cycle system following a shutdown of the steam turbine lasting at

least 48 hours.

b. Warm and hot start-ups include all startups that are not a cold startup of the 3-on-1

combined cycle system.

o It is suggested that the definitions be the same as the FDEP permit.

2. Shutdown is defined as the period beginning with the lowering of equipment from normal 

operating load and lasting until fuel flow is completely off and combustion has ceased.

3 The duration of startup and shutdown periods shall be recorded and reported semi-annually as

part of Condition IX. I.4.not exceed the following in any 24 hour period, for the CT unit, as

verified by the CEMS:

Duration

Cold Start 4 hours

Warm and Hot Start 2 hours

Shutdown 2 hours

o This condition limits the actual duration of cold start, warm start and 

shutdowns. For a 12-month rolling average the limited start-ups and shut downs 

are included in the proposed limit as discussed above and restricting the length 

for these intermittent conditions is unnecessary. In addition, there may be 

circumstances during a 24-hour periods that multiple starts or shutdowns are 

necessary. However, the 12-month rolling average as proposed for PEEC would 

not be exceeded if multiple startups and shutdowns occurred in any 24-hour 

period. Please note that the FDEP condition only provides for an exclusion of 

emissions during these operating conditions and not an express time limit for 

these operating conditions.

EPA Response: EPA agrees that since the BACT limits of the combustion turbines apply at 

all times, including times of startup and shutdown, it is unnecessary to limit the duration of 

startups and shutdowns. The permit shall be revised accordingly and the limits on the duration 
21

of startup and shutdown will be removed. This also addresses the concern that the EPA and 

FDEP permits did not contain identical definitions. 

20. Comment:

E. Auxiliary Equipment Emission Limits and Work Practices

1. At all times during operation (excluding during maintenance activities and failures), 

including equipment startup and shutdown, Permittee shall not discharge or cause the 

discharge of emissions from each unit into the atmosphere in excess of the following, and 

shall otherwise comply with the following specifications on a 12-month rolling total:

o FPL requests that maintenance and failures be excluded for these minor 

sources of GHG emissions. This is especially important for circuit breakers 

using SF6 where it is difficult if not impossible to determine losses form 

maintenance activities and failures could occur.

EPA Response: BACT limits apply at all times; however, in the event of a malfunction or 

emergency, EPA can use its enforcement discretion, if necessary. Furthermore, if it is 

impractical to monitor emissions during maintenance and/or malfunction periods, EPA may 

establish a work practice standards in lieu of a numerical BACT limit. As described in 

Condition IX.E.7, the GHG (SF6) limit is really a work practice standard since emissions are 

not being quantified to show compliance. EPA believes it will eliminate confusion to remove 

the 2.25 TPY emission limit included in Condition IX.E.1 and more clearly identify the work 

practice standards described in Condition IX.E.7 as BACT for the circuit breakers. 

4. Except during an emergency, the The Emergency Generators shall be limited to operation

of the engine for maintenance and testing purposes as an “emergency stationary RICE” as

defined in 40 Part 63 Subpart ZZZZ. Annual hours of operation for Emergency

Generators, for maintenance and testing, shall not exceed 100 24 hours per 12-month 

rolling total for each generator.

o This condition is more restrictive than the FDEP permit and establishes a limit for

maintenance per 12-month rolling average. This unit is regulated under Subpart IIII 

and is classified as an “Emergency Stationary RICE” under Subpart ZZZZ. 

These regulations have operating limits that would be applicable. Also, the 

term “emergency” is not defined in EPA PSD regulations and could be

misinterpreted. The 100 hours per 12-month rolling average should be the

BACT limit as determined in the emission limits in the permit. Also, this is 

consistent with the FDEP permit.

6. Except during an emergency, the The Fire Pump Engine shall be limited to operation as

an “emergency stationary RICE” as defined in 40 CFR Part 63 Subpart ZZZZ of the

engine for maintenance and testing purposes. Annual hours of operation for the Fire Pump

Engine, for maintenance and testing, shall not exceed 24 hours per 12- month rolling total.

o Same comments as the emergency generator
22

EPA Response: EPA agrees that 24 hours of operation for each emergency generator is 

unnecessarily restrictive since the emissions calculations included in the appendix of the 

application utilized 100 hours per year per generator. Condition IX.E.4 shall be revised to allow

100 hours of operation for each emergency generator per 12-month rolling total. Furthermore, 

the language of Condition IX.E.4 and IX.E.6 will be revised to include clarifying references to 

40 CFR Part 63 Subpart ZZZZ, as requested by the applicant.

7. Circuit Breakers shall be used as electrical interrupters in the event of a power surge, 

shall be equipped with low-density pressure alarms, and shall be visually inspected on a

daily basis. In addition, Permittee shall implement a maintenance program that maintains

the integrity of the breakers and minimizes SF6 emissions. breakers shall be inspected

by the manufacturer once every 5 years, and shall be overhauled at the end of their 20

year life cycle. Records of inspection shall be kept in accordance with Condition IX.I.

Given that this is a work practice standard, no quantification of SF6 emissions is required

for compliance with the BACT emissions limit of 2.25 tons per year of CO2e per breaker. 

Maintenance activities and failures are not considered in the BACT emission limit.

o The daily inspection appears unnecessary since these breakers will have a 

performance standard and checked on a regular basis to meet requirements of

40 CFR Part 98 Subpart DD. The primary way to measure SF6 is by weighting the 

equipment and using a mass balance to determine emissions. The performance

standard cited in the information provided to EPA was the International

Electrotechnical Commission (IEC) standard of 0.5 percent (IEC Standard 62271-1,

2004) that is recognized by the EPA SF6 Reduction Partnership as an effective

criterion for minimizing fugitive SF6 emissions. The manufacturer inspection

every 5 years and overhaul should be replaced with “periodic inspections 

according to manufacturer recommendations”. Please note that this equipment

is sealed. As discussed previously, it is difficult to measure losses from maintenance

activities and failures could occur. Therefore, not including these as part of the

BACT limits is suggested.

EPA Response: EPA agrees that daily inspection of the circuit breakers is unnecessary since 

they will be equipped with a continuous low-pressure alarm. EPA believes it is more 

appropriate to require the Permittee to follow manufacturer’s recommendations; therefore, EPA 

revised the permit to require “periodic inspections according to manufacturer’s 

recommendations” In lieu of the set 5 and 20 years inspection requirements prescribed in the 

draft permit. EPA will revise Condition IX.E.7 to remove the reference to the 2.25 TPY;

however, the commenters request to eliminate maintenance activities and failures will not be 

included as requested. See EPA’s Response to Comment 20 above regarding the application of 

BACT limits to maintenance activities and failures.

8. The Temporary Construction Boilers shall be limited to use only during the Project 

construction period to provide steam during construction activities that includes but not

limited tofor HRSG cleaning and associated steam blows. Annual hours of operation for

each boiler shall not exceed an aggregate of 3,000 1,500 hours per 12- month rolling

total. The Temporary Construction Boilers will be permanently shut down and removed 

from the facility once commercial operation of the Project begins.
23

o The underlined text appears only to apply to the HRSG and is too restrictive as 

other activities may need steam. Steam is needed to clean steam turbine 

connections and anywhere steam piping is used. Since steam is used 

throughout the 3-on1 combined cycle unit the location of the boiler is 

important. A boiler may be close to where more hours of steam is needed while 

the other boiler is located in a different area. Having an individual hour limit 

would require potentially moving a boiler to complete construction. Also, the 

FDEP permit allows an aggregate of 3,000 hours for the two boilers.

EPA Response: EPA agrees that the limits on the allowable use of steam is too restrictive

and will revise the permit condition as requested by the applicant. Since GHGs are a global 

pollutant and there are no short-term air quality standards associated with GHGs, EPA also 

agrees that the allowable hours of operation for the temporary construction boilers can be 

revised to the aggregate of 3,000 hours per 12-month rolling total without any negative 

environmental impacts. EPA amended Condition IX.E.8 to allow this flexibility.

21. Comment:

F. Continuous Emissions Monitoring System (CEMS) for CTs

1. At the earliest feasible opportunity after first firing of CTs and before CTs

commence commercial operation (as defined in 40 CFR § 72.2), in accordance with

the recommendations of the equipment manufacturer and the construction contractor:

a. Permittee shall install, calibrate, and operate a CEMS for each CT that measures

stack gas CO2 concentrations in parts per million by volume (ppmv). The

concentrations shall be corrected to 15% O2 on a dry basis. No later than the end of

the shakedown period as defined in Condition IX.J. or upon commencing commercial

operations, whichever comes first, Permittee shall also maintain, certify, and qualityassure a CEMS for each CT that measures stack gas CO2 concentrations in ppmv,

and shall conduct initial certification of the CEMS in accordance with Condition

IX.F.6. The concentrations shall be corrected to 15% O2 on a dry basis.

2. The CO2 CEMS shall meet the applicable requirements of 40 CFR Part 75.

3. Each CEMS shall complete a minimum of one cycle of operation (sampling,

analyzing, and data recording) for each successive 15-minute clock-hour period.

4. The initial certification of the CEMS may either be conducted separately, as specified

in 40 CFR § 60.334(b)(1), or as part of the initial performance test of each emission

unit. The CEMS must undergo and pass initial performance specification testing on or

before the date of the initial performance test.
24

5. The CEMS shall meet the requirements of 40 CFR § 60.13. Data sampling, analyzing,

and recording shall also be adequate to demonstrate compliance with emission limits

during startup and shutdown.

6. Not less than 90 days prior to the date of initial startup of the facility, the Permittee

shall submit to the EPA a quality assurance project plan for the certification and 

operation of the CEMS. Such a plan shall conform to EPA requirements contained in

40 CFR Part 60 Appendix F for CO2, and 40 CFR Part 75 Appendix B for stack flow.

The plan shall be updated and resubmitted upon request by EPA. The plan shall

specify how emissions during startups and shutdowns will be determined and

calculated, including quantifying flow accurately if calculations are used.

7. The gas turbine CEMS shall be audited quarterly and tested annually in accordance

with 40 CFR Part 60 Appendix F, Procedure 1. Permittee shall perform a full stack

traverse during initial run of annual RATA testing of the CEMS, with testing points

selected according to 40 CFR Part 60 Appendix A, Method 1.

8. Permittee shall submit a CEMS performance test protocol to the EPA no later than 30

days prior to the test date to allow review of the test plan and to arrange for an

observer to be present at the test. The performance test shall be conducted in accordance

with the submitted protocol and any changes required by EPA.

9. Permittee shall furnish the EPA a written report of the results of performance tests

within 60 days of completion via the contact information provided in Condition X.

10. The stack gas volumetric flow rates shall be calculated in accordance with the fuel

flowmeter requirements of 40 CFR Part 75 Appendix D in combination with the

appropriate parts of EPA Method 19.

12. Permittee shall measure and record, for each CT, the actual heat input (Btu) on an

hourly basis.

13. Permittee shall measure and record, for each CT, the following:

a. Net energy output (MWhnet and kWhnet) on an hourly basis;

b. Pounds of CO2 per net energy output (lb CO2/MWhnet) on an hourly basis;

c. Net heat rate (Btu/kWhnet) on an hourly basis, based on total heat input for the facility;

d. The type of fuel (natural gas or ULSD) burned on an hourly basis;

e. The 12-month rolling average emission rate of lb CO2/MWhnet and Btu/kWhnet. The
25

12-month rolling average shall be based on the average hourly recordings summed for

each operating month and averaged with the respective rates from the previous 11 months for

each fuel type.

• These conditions appear to be written for NOx or CO. For CO2 CEM, EPA methods 

have already been established that can accurately measure CO2 emissions. CO2 

monitoring have been implemented since the Acid Rain Program and FPL offers the 

following conditions developed by an experienced EPA CEMs engineer.

EPA Response: EPA agrees with the applicant that the CEMS conditions in the draft permit are 

more appropriate for non-GHG pollutants. EPA believes it is more appropriate to align the 

existing CO2 monitoring being done at the facility for the purposes of Acid Rain to that required 

by this permit. EPA will revise Condition IX.F as requested by the applicant (see below), with the 

exception of Condition IX.F.1, which will now include the requirement to install, certify, operate 

and maintain the monitoring systems which is more consistent with Part 75 (See 75.1(b)(1) and 

75.10(a)(3)(i)). These revisions allow the integration of the existing CO2 monitoring being done 

by the facility, since it will also assure compliance with the GHG BACT limits in this permit.

F. Continuous Monitoring of CO2 for CTs

1. Permittee shall install and certify monitoring systems required for quantifying CO2

emissions from each CT in accordance with the applicable requirements of 40 CFR Part

75. Consistent with §75.4(b), all applicable certification tests shall be completed within

180 calendar days after the date the unit commences commercial operation (as defined in

40 CFR 72.2).

2. Following initial certification, the CO2 continuous measurement system shall be 

quality assured in accordance with the applicable requirements of 40 CFR Part 75.

3. The CO2 continuous measurement system shall be capable of producing hourly 

determinations of CO2 mass emissions in tons per hour (tons/hr).

4. In accordance with §75.62, an initial monitoring plan shall be submitted identifying the

methodology for which CO2 mass emissions will be continuously monitored. The initial 

monitoring plan shall be submitted no later than 21 days prior to the initial certification tests.

5. Permittee shall provide notifications as specified in §75.61 for any event related to the

continuous measurement of CO2.

6. Permittee shall measure and record, for each CT, the actual heat input (Btu) on an

hourly basis in accordance with 40 CFR Part 75

7 Permittee shall measure and record, for each CT, the following on an hourly basis:

a. Energy output rate (MW );
26

b. CO2 mass emission rate (tons CO2/hr);

c. Heat Input rate (mmBtu/hr);

d. Unit Operating Time as described in §75.57(b)(2)

e. The type of fuel (natural gas or ULSD) burned;

8. Permittee shall calculate and record, for each CT, the following on a monthly basis:

a. Monthly average CO2 emission rate (lbs CO2/MWh) calculated as the sum of each 

hourly CO2 Mass emission rate times the unit operating time for the hour divided by the 

sum of the recorded energy output rates times the unit operating time for the hour for all

hours of operation in each month. If more than one fuel is utilized in a month, a separate

average CO2 emissions rate shall be calculated for each fuel.

b. Monthly average heat rate (Btu/kWh) calculated as the sum of each hourly heat input

rate times the unit operating time for the hour divided by the sum of the recorded energy

output rates times the unit operating time for the hour for all hours of operation in each

month times 1,000. If more than one fuel is utilized in a month, a separate average heat

input rate shall be calculated for each fuel.

9. Permittee shall calculate and record, for each CT, the following on an annual basis:

a. The 12-month rolling average CO2 emission rate (lbs CO2/MWh) (for each fuel 

combusted in the previous 12 months) shall be calculated as the sum of each monthly

average value times the monthly energy output (MWh) divided by the sum of the energy

output (MWh) generated during the 12 month period.

b. The 12-month rolling average heat rate (Btu/kWh) (for each fuel combusted in the

previous 12 months) shall be calculated as the sum of each monthly average heat rate

value timese the monthly energy output (kWh) divided by the sum of the energy output

(kWh) generated during the 12 month period.

• The last condition related to calculating the 12-month rolling average needs to factor in

the amount of generation produced each month to determine compliance. The condition as

originally written uses the averages of month rates. This can lead to an erroneous

calculation where generation was very low for one of more months, coupled with a high

lbCO2e/MWhr. This averaging method will artificially increase the 12- month rolling

lbCO2e/MWh emission rate. A calculation is shown below using 100% load for 10 

months of operation and two low load conditions with higher GHG emission rates for

2 months of operation. The example calculations are based on: 1. a weighted average based

on the amount of monthly generation (the most accurate determination of a 12-month

rolling average emission rate), and 2. an average of monthly average emission rates. As

shown, the 12-month rolling by averaging the monthly lb CO2e/MWh is 770 lb

CO2e/MWhr while using a weighted average based on the amount of generation the 12-
27

month rolling average is 763 lb CO2e/MWh. This is about a 1% difference artificially

created by the averaging method.

Example Calculation of Aggregate versus Monthly Average:

Month Days lb CO2e MWh lbCO2e/MWhr

1

2

3

4

5

6

7

8

9

10

11

12

31

28

31

30

31

30

31

3

30

3

30

31

669,600,000

604,800,000

669,600,000

648,000,000

669,600,000

648,000,000

669,600,000

20,520,000

648,000,000

20,520,000

648,000,000

669,600,000

877,920

792,960

877,920

849,600

877,920

849,600

877,920

25,416

849,600

25,416

849,600

877,920

763

763

763

763

763

763

763

807

763

807

763

763

Sum: 6,585,840,000 8,631,792

Average 

Monthly Rates 

Adjusted for 

Generation 

Amount

Average of

Monthly Rates

763 lb

CO2e/MWh

770 lb

CO2e/MWh
28

EPA Response: EPA agrees with the commenter’s assessment that the proposed 12-

month average calculation methodology introduces a bias for months with little operation. 

Consequently, EPA will revise the draft permit as requested by the applicant. See final 

permit Conditions IX.F.1 - IX.F.9.

22. Comment:

G. Performance Tests

1. Stack Tests

a. Within 60 days after achieving normal operation, but not later than 180 days

after the initial startup of equipment, and, unless otherwise specified, annually

thereafter (within 30 days of the initial performance test anniversary), Permittee shall 

conduct performance tests (as described in 40 CFR § 60.8) as follows:

a.. CO2 emissions from each CT

b. Permittee shall submit a performance test protocol to EPA no later than 30 days

prior to the test to allow review of the test plan and to arrange for an Agency

observer to be present at the test. The performance test shall be conducted in

accordance with the submitted protocol, and any changes required by EPA.

c. Performance tests shall be conducted in accordance with the test methods set forth

in 40 CFR § 60.8 and 40 CFR Part 60 Appendix A, as modified below. In lieu of

the specified test methods, equivalent methods may be used with prior written 

approval from EPA:

i. EPA Methods 1-4 and 3B for CO2 emissions, and

ii. the provisions of 40 CFR § 60.8(f).

d. Upon written request and adequate justification from the Permittee, EPA may

waive a specific annual test and/or allow for testing to be done at less than maximum 

operating capacity.

e. For performance test purposes, sampling ports, platforms, and access shall be

provided on the emission unit exhaust system in accordance with the requirements of

40 CFR § 60.8(e).

f. Permittee shall furnish the EPA a written report of the results of performance

tests within 60 days of completion to the address listed in Condition X.

o Performance Tests are unnecessary since CO2 emissions are continuously 

monitored using Federal methodologies (40 CFR 75) and for which the data 

are electronically validated and submitted using EPA required software.

EPA Response: According to Part 75, initial certification of the monitoring system is 

required, which involves performance testing; therefore, EPA agrees that additional 

performance testing is unnecessary. EPA revised the draft permit to stipulate that 
29

certification must be performed in accordance to 40 CFR 75 (see Condition IX.F) and 

removed the requirements of permit Condition IX.G. [Note: Condition IX.G in the final 

permit is now an unrelated compliance condition]

23. Comment:

H. Monitoring for Auxiliary Equipment

1. Permittee shall install and maintain fuel measurement equipment, including but not

limited to fuel tank gages and fuel receipts, an operational non-resettable totalizing 

mass or volumetric flow meter to measure fuel use in each fuel line for the 99.8

MMBtu/hr boiler (Auxiliary Boiler), the 2,250 kW emergency use engines (Emergency 

Generators), and the 300 hp emergency-use firewater pump (Fire Pump Engines), to Fuel

use shall be recorded monthly and totaled every month for the previous 12 months.

o Much of this equipment has not been purchased and there are numerous 

methods to measure fuel use including maintaining fuel records for tanks. For 

example, the diesel engines typically have a dedicated tank where 

measurements can be obtained. Given the minor emissions and limited 

operation of these units having a fuel flow meter with recording is unnecessary to 

demonstrate compliance with the BACT limit.

3. Permittee shall install and maintain a leak detection system on the circuit breakers that

signals an alarm in the facility’s control room in the event that any circuit breaker loses

more than 10% of its dielectric fluid. The owner/operator shall promptly respond to any

alarm, investigate the circuit breaker involved, and fix any leak-tightness problems that

caused the alarm.

o This condition is unnecessary with the requirements of Condition E.7. The 

breakers are sealed equipment and with regular inspections provide assurance that 

SF6 emissions are limited.

EPA Response: EPA agrees with the assessment that the stipulated methods for the 

monitoring of auxiliary equipment that has yet to be purchased may be unreasonably restrictive. 

Furthermore, EPA agrees that Condition IX.H.3 is unnecessary given that the SF6 BACT limit 

is a work practice standard. See EPA’s response to comment 20 for more discussion on SF6. 

The permit will be revised to include a broader monitoring requirement that is applicable to a 

wider range of equipment. See Condition IX.H.1.

24. Comment:

I. Recordkeeping and Reporting

6. A period of monitor down-time shall be any unit operating clock hour in which 

sufficient data are not obtained by the CEMS to validate the hour for CO2 according to

40 CFR Part 75.
30

o Suggest defining monitor-down time according to an existing regulatory 

requirement.

EPA Response: EPA agrees with this assessment. EPA revised this condition to reference 40 

CFR 75. See Condition IX.I.6.

25. Comment:

J. Shakedown Periods

The combustion turbine and auxiliary equipment emission limits and requirements in

Conditions IX.C, IX.D, and IX.E shall not apply during combustion shakedown periods 

for the commissioning of the 3-on-1 combined cycle unit. Shakedown is defined as the 

period beginning with initial startup and ending no later than initial performance testing, 

during which the Permittee conducts operational and contractual testing and tuning to 

ensure the safe, efficient and reliable operation of the plant. The shakedown period shall 

not exceed 90 180 days for each fuel. With the exception of Conditions IX.C. D and E

during shakedown periods.T The requirements of Section III of this permit shall apply at 

all times.

o The 3-on-1 combined cycle unit requires integration of each CT/HRSG train 

with the steam turbine. This typically involves operation of the CT and 

combustion tuning prior to tying into the steam turbine. In addition, each fuel 

will need separate commissioning periods as their combustion processes are 

quite different. The last sentence appears to contradict the first sentence. This 

phrase was added for clarification.

EPA Response: EPA agrees with the request for the maximum allowed time of 180-days for 

shakedown; however, EPA does not believe it is necessary to have a separate 180-day period 

for each fuel type. EPA revised Condition IX.J to allow for a 180-day shakedown period.

26. Comment:

K. Global Warming Potential (GWP)

For the purposes of showing compliance with any GHG emission limit in this permit, the

GWP factors listed in 40 CFR Part 98 Subpart A, Table A-1 as of the date of this permit 

shall be used. The GHG emission limits for CTs/HRSGs were developed using 40 CFR

Part 98 Subpart C emissions factors (Tables C-1 and C-2). The GHG emission limits for

the CTs/HRSGs may be adjusted after agency review if the actual emissions in

lbCO2/MMBtu determined from the CEMs and fuel sampling are higher than those used

as a basis of this permit. The current GWP and emission factors are listed below:

GHG 

Pollutant

GWP Factor Emission

Factor

(kgCO2/M

M Btu)

CO2 1 53.02

CH4 21 0.001

N2O 310 0.0001

SF6 23,900
o The use of the 40 CFR Part 98 emission factors could be different than the 

emissions that actually occur using pipeline natural gas in the CTs/HRSGs. 

FPL relies on several sources of natural gas and differences may occur. FPL 

requests that this condition include the possibility of an adjustment to the 

lbCO2/MWh emission limit after agency review that would be based on actual 

data during operation.

EPA Response: On September 11, 2013, EPA proposed to amend 40 CFR Part 98 (GHG 

Reporting Rule), which includes revisions to the Global Warming Potential (GWP) factors. 

As of the issuance date of this permit, the proposed changes have not been finalized. 

Consequently, this condition was added to the permit solely to ensure the correct GWP 

factors are used for determining future compliance with the CO2e emission limits. However, 

the emission factors used in the application are well established and used at the risk of the 

applicant. The applicant is responsible for using the most reliable emissions factors available.

If in the future, based on new data from source specific tests, it may necessary to revise the 

permit, EPA will reevaluate the need at that time. EPA will not revise this condition as

requested.