1 

## 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 2 2 , 20132 

### 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

.......... 183 

### Introduction

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

Significant Deterioration (PSD) pe rmit for Greenhouse Gases (GHGs) to Flo rida 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 p eriod 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 al so 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 obt ained 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 com ments 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 A venue, 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 the4 permit of the Po rt 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 n ot 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 s ignificant 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 t he 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 an d 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

exi sting 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. F urthermore, the project attracted very little media interest; EPA was able to

locate only two relevant article s 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 whe ther 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 hol d 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 permittin g 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

pre paration 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 her5 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 the refore 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 § 124.1 0, which sets forth

the publi c 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 th e

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 t he procedures governing PSD permit appeals are set forth at 40 CFR § 124.19. The

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

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

conditions of the final permi t, 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 perio d. 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 intereste d 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: CO 2 , CH 4 , NO

x , SF 6 , 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 atm osphere. 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, a nd the environment is

provided in EPA’s “Technical Support D ocument 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 stationary6 sources of air pollution in Florida. The State of Florida has jurisdict ion over PSD permitting

for all NSR

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

- GHG

emissions for the f acility 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 ( CO 2 e ) basis

.

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

am truly concerned w ith 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, o n 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/n sr/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 124.1 0 ). 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

every one 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 t he 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 comply7 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 propose d

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, Sect ion 7 of the Endangered Species Act require d EPA to

consult with NOAA prior to its final permit action

. The Endangered Species Act process

can tak e 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 ha wksbill 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 a s 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 e ffect of GHG emissions on climate change and impacts of climate change at

s pecific 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.8 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 site

specific b asis 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 ch oose 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 po llution 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 reductio n 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 oppose d 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 tec hnology 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 low er

- 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

effici ent 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 a nd 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 BA CT 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 at9 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 a n 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 th at 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 sourc e 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 energ y, 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

tur bine 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 t echnologies for purposes of the

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

factors in dependent 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 applicatio n

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.” “Combi ned 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 t echnology 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 e nergy e fficiency 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

, M itsubishi P ower10 S ystems (MPS) “J” and Siemens “H .” EPA concluded that t he 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 a nd 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 ha ve 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 rega rdless 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 whi ch 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 Worksh o p Manual at B.21

- B.22). While this observation has

been made in the cont ext 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 capacitie s

.

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 Lo w 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."11 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 effic ient 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 th e 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 C omment s 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 pro ject 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 a n “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 pro posed 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 emit ting 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 stan dard 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 n ot provide any

restrictions on the use of fuel oil, other than an arbitrary cap of 1000 hours on a 12

- month12 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 li mit 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 technol ogies 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 per mit 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 c ommenter 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 info rmation provided in the application as well as on additional information

submitted by the applicant by email on November 16, 201 2

. S ee email and attachment dated

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

additio nal 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, 201 2 email, t he

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

the Final Order Granting Determin ation 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 e ffects th at would have on the fuel

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

on recent hurricanes that supports the requested a m ou n t of backup fuel is justified. On the

contrary, t he commenter has not provided a ny support for the suggested limit of 100 hours

per year per of ULSD n or 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 withdr ew this proposed

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

Plants. I n the new standard, as with the previous proposal, EPA does not distinguish13 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 CO 2 /MWh)

. T he 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.” A lthough

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 requi rement 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 t o, 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 i s 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 CO 2e 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 c leaner 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 combust ion 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 ver y 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 n umerous 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 s econd 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 compressor s 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 o f 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 i s correct that the Natural Gas C ompressor s are the

second highest contributor of GHG emissions in this project (at 55,313 TPY of CO 2 e), it

s hould also be noted that the compressor emissions only constitute 1.2% of the total G HG

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.”

C ondition IX.E.1 of the permit limits the emissions of the gas compress ors to 55,313 TPY

of CO 2 e, 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 th ough 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 page s 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 criteri on for the

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

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

page 8 of May 8, 2012 RTC letter). Further more , 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 g iven the relatively small amount of GHG emissions from this

unit . EPA concludes that the BACT analysis performed and the suppleme ntal information

provided by the applicant in the May 8, 2012

, RTC letter is adequate considering the15 extremely low volume of G HG 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 t he

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

impose more detailed complianc e 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 . T he term “ e mergency” 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 f acility 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, bu t 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 calcu lation 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 I X .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 ef ficient 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. If16 Palmdale is able to achieve 774 lb CO 2/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 CO 2 /MWh referenced by the commenter (Palmdale Hybrid

Power Proj ect) 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

electric ity when showing compliance with the 774 lb CO 2 /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

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

BACT limit of 830 lb CO 2 e/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 P almdale’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 R ACT/BACT/LAER Clearinghouse database as well as other known PSD

pe rmits 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 G eneral Electric “ H ” system turbine as comparable to the

MPS “ J ” and Siemens “ H ” turbines being considered by the applicant for th is 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 adequat e to demonstrate the applicant is pr oposing 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 efficienc y beyond those being

considered for this project.

16. Comment: Startup Pe riods 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 start up 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 design ed to be able to start up and dispatch17 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 init ially 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 cau ses 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 start ups), 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

fl exibility and reduce emissions associated with startups.

The Region must consider whether a fast

- start turbine design available from GE or similar fast

start 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 B ACT 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 b lanket 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 a ll times, including startup/shutdown /malfunction periods, therefore

, it is no t necessary to

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

17. Comment: BACT Analysis for SF 6 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 leak18 SF6. The Region determined that the BACT limit for SF6 for the circuit brea kers 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 shou ld 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

sho uld be revised to include a condition forbidding its use.

EPA Response: FPL has confirmed that SF 6 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. C o m bu s t ion Tu r b i n e ( C T ) E m ission L i m i t s

1. E x ce pt a s not e d b e low und e r C onditions I X

. D a nd J

, on a nd af t e r the d a te of initi a l

st ar tup, P er mitt e e s h a ll not dis c h a r g e or ca u s e t he dis c h a r g e of e missions fr om the C T

Unit into the a tmosph er e in e x ce ss of the f ollowin g :

• T h e s h ak e do w n c o n diti o n s h o u ld be c it e d in t h is c o n ditio n

.

. E m ission L i m it ( pe r C T )

( n a t u r al gas f i r i n g) E m ission L i m it ( pe r C T )

( f

u e l oil b u r n i n g)

G HG L i m it ( as CO 2 e) 832 lb C O2 e /M W h n e t

output ( 12

- month r olling

a v er a g e)

877 lb C O 2 e /M W h n et

output ( 12

- month r olling

a v er a g e) 1,176 lb C O2 e /M W h n e t

output ( 12

- month r olling

a v er a g e)

o F PL r e q u e st t h at E PA c o n sid e r t h e propos e d as t h e BAC T l i m it f or P E

E C t h at

as d e s c rib e d in t h e a ppli c ation i n c l u d e s all op e rati n g c o n ditio n s s u c h as

start u ps, s h u tdo wn s, f u e l s w it c h e s, 2 a n d 1 C T o p e ration w ith t h e st e am t u rbi n e

op e rati n g at lo w e r l e ss eff i c i e n t loads, low load op e ration on 1, 2 or 3 C Ts, d u al

f

u e l op e ration ( oil on o n e C T a n d gas on t w o C T s )

, m al f

un c ti o n s of t h e C Ts or

st e am t u rb i n e

, C T p e r f

or m a n c e d e t e rioration f rom n e w a n d c l e a n

, a n d u n it

e n v iro n m en tal t e st i n g. T h e BAC T a n al y sis i n c l u d e d i n f

o r m ati o n o n BA C T

l i m its f or t w o gas

- o n ly f ir e d c o m bi n e d cyc le pr o j ec ts t h at w e re 918 a n d 950 lb

C O2 e /MW ( n e t) f or p e rmits is s u e by E PA R e gio n s 6 a n d 9, r e sp ec ti ve l y

. I n d ee d,19 si n c e t h e P EE C GHG P S D A ppli c ation h as b ee n s u b m itt e d s eve ral ot h e r GHG

P

S

D p e r m its h a v e b ee n iss u e d f or si m ilar c ombi n e d cyc l e proj e c ts t h at h a ve

BAC T l i mits m u c h h i g

h e r t h an t h ose propo s e d f or P EEC

. T h is i n c l u d e d

C

alpi n e’ s D ee r Park E ne rgy C e n t e r ( P

S

D

- T X

- 9 79

- GHG) a n d C alpi n e C h a nn e l

En e rgy C e n t e r ( LL C )(

P

S

D

- T X

- 955

- GHG) w ith l i m its of 920 lb C O 2 e / M W ( n e t)

f

or e a c h proj ec t. C l e arl y

, eve n i n c l u di n g oil f iri n g as part of t h e 12

- m o n th

rolli n g a ve rag e

, e stabl i s h e s an approp r iate B AC T e m issi o n l i mit f o r t h i

s

Proj ec t. Mor e o ve r, t h e propos e d e m issi o n l i mit f or U S LD oil c a nn ot be m e t as

t h is f u e l w ill lik e ly be u s e d in a m u c h di ffe r e n t f as h ion in a n y 12

- m o n th rolli n g

p e riod t h an t h e pr i m a r y f u e l, n at u ral gas. T h e e m is s io n s pro v id e d in t h e

appli c ation a n d add i ti o n al i n f

o r m ation w as b a s e d on f u ll load at 75 d e

gr e e F

t u rbi n e i n l e t. If oil is u s e d in t h e s u m m e r m o n t h s t h e t u r b i n e i n l e t t e mp e rat u re

w ill lik e ly be m u c h h i g

he r t h e r e by r e d u c i n g t h e h e at rat e

. T h e a m o un t of ti m e

f

or start u p a n d s h u td o w n u s i n g oil w i ll be r e lati ve ly h igh c o m par e d to t h e

a m o un t of op e ration e sp ec ially wh e n o n ly t e st i n g is p e r f

or m e d as t e s t i n g is

c o n d u c t e d f or s h ort d u r atio n s. T h e 1,176 lb C 2 e /MWh as an i n di v id u al l i m i t

c a nn ot be a c h i eve d f or U S LD oil f or t h e r e aso n s c it e d abo ve

.

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, d ue 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 , w hile the description of how

BACT was set on page 13 of the Prelimin ary 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 C O

2 e /M W h for natural gas and 1,248 C O

2 e /M W h for

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

not being able to meet the 1,176 lb CO 2 e/MWh limit on an individual basis.

2. E ac h The th r e e C Ts a sso c i a t ed with P EEC C T s h a ll not op era te f i r i n g Ult r a L ow S ul f ur

Di e s e l ( U L S D) mo r e th a n an a gg r e g a te of 3,000 1,000 hou r s / y e a r on a 1 2

- month r olling

tot a l. The P er mitt e e sh a l l monitor a nd rec o r d the numb e r of hou r s e ac h C T op era t e s on

U L S D to be rec o r d e d m o nth l y a nd tot a l e d e v e r y m onth f or the p re vious 12 months.

o T h is c o n dition is r e q u e s t e d to be t h e sa m e as t h at in t h e F D E P a u t h o rizatio n

,

t h at is: “Op e ratio n : T h e h o u rs of op e ration of U n it 5 are n ot l i mit e d ( 8,760

h o u rs p e r ye ar )

. UL S D f u e l oil m ay be f i r e d u p to t h e f u e l e q u i v al e n t o f 3,000

h o u rs aggr e gat e d o ve r t h e t h r e e C TGs d u ri n g a n y c al e n dar y e ar. [ A

ppli c ation

No. 0110036

- 010

- AC ; R u le 62

- 210.200 ( PT E

)

, F

. A

. C .] T h is allo w s f l e

xibility i n

op e ration a n d w o u ld n o t i n c r e ase GHG e m issio n s. In c o n trast, if oil is u s e d a n d

o n ly o n e C T is r e q u ir e d it w ill lik e ly be t h e C T t h at op e rat e s b e st wh e n oi l

- f

ir e d.

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 to20 3,000 hours aggregated over the three CTs during a 12

- month period without any negative

environmental impacts

. EPA amended Condition I X

. C.2 to allow this flexibility

.

19. Comment:

D. R e qu i r e m e n t s du r i n g C o m bu s t ion Tu r b i n e S t a rt u p a n d S hu t d o w n

1. S t ar tup is d ef in e d a s the c omm e n ce m e nt of op era tion of a n y e missio n s unit whi c h h a s shut

down or cea s e d op e r a tion f or a p er iod of ti m e su ff i c i e nt to ca use t e mp era tu re

, p r e ssu re

,

c h e mi ca l, or pollution c ont r ol d e vi c e imb a l a n c e s, whi c h re sult in e x ce ss e missions a bove the

limits in C ondition I X. C

.

a

. A c old st ar tup m ea ns a st ar tup wh e n the C T h a s not b ee n in op era t i on du r ing the

p rece di n g 48 hou r s

. A c old “ st ar tup of the st ea m tu r bine s y st e m” is d ef i n e d a s st ar tup of

the 3

- on

- 1 c ombin e d c y c le s y st e m f ollowi n g a s hutdown of the st e a m t u r bine l a sting a t

l ea st 48 hou r s

.

b. W ar m a nd hot st ar t

- u ps in c lude a ll st ar tups th a t ar e not a c old st ar tu p of the 3

- on

- 1

c ombin ed c y c le s y st e m

.

o It is s u gg e s te d t h at t h e d e f i n i t i o n s b e t h e sa m e as t h e FD E P per m i t

.

2. S hutdown i s d ef in e d a s the p er iod b e g inni n g with the low er ing of e quipm e nt fr om no r m a l

op era ti n g lo a d a nd l a sti n g until f u e l f low is c omp l e t e l y o f f a nd c ombustion h a s cea s e d.

3 The du ra tion of st ar tup a nd shutdown p er iods sh a ll be rec o r d ed a nd r e p o r t e d s e mi

- a nnu a l l y as

p ar t of C ondition I X. I

. 4. not e x cee d the f ollow i ng in a n y 2 4 hour p e r i o d, f or the C T unit, a s

v er i f i ed b y the C EM S :

Du ra tion

C old S t ar t 4 hou r s

W ar m a nd Hot S t ar t 2 hou r s

S hutdown 2 hou r s

o T h is c o n dition l i mits t h e a c t u al d u ration o f c old start, w arm s t art a n d

s hu tdo w n s. F or a 12

- m o n th roll i n g a ve rage t h e l imit e d start

- u ps a n d s h u t do w n s

are i n c l u d e d in t h e pro p os e d l i m it as dis c u ss e d abo v e a n d r e stri c ti n g t h e l e n gth

f

or t h e se i n t e r m itt en t c o n ditio n s is u nn ece ssar y

. In additio n

, t h e re m ay be

c ir c u m st a n ce s d u ri n g a 24

- h o u r p e riods t h at m u ltiple starts or s h u t d

o wn s are

n ece ssar y

. Ho w eve r, t h e 12

- m o n th ro l li n g a ve r a

ge as propos e d f or P EE C w o u l d

n ot be e x cee d e d if m u l tiple start u p s a n d s hu t d

o wn s o cc u rr e d in a n y 24

- h o ur

p e riod. Pl e ase n ote t h at t h e F D E P c o n dition o n ly pro v id e s f or an e x c l u sion of

e m issi o n s d u ri n g t h e se op e rati n g c o n diti o n s a n d n ot a n e xpr e ss t i m e l imit f or

t h e se op e rati n g c o n diti o n s.

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 duration21 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 . A u xilia r y E q u i p m e n t E m ission L i m i t s a n d Wo r k P r a ct i c e s

1. At a ll tim e s du r i n g o p era tion ( e x c luding d u r ing m a int e n a n c e ac tiviti e s a nd fa ilu re s )

, in c luding e quipm e nt st ar tup a nd shutdown, P er mitt e e sh a ll not dis c h ar g e or ca use the

dis c h a r g e o f e missions f r om eac h unit into the a t mosph er e in e x ce ss of t h e f ollowin g

, a nd

sh a ll oth er wise c omp l y with the f ollowing sp e c i f i ca tions on a 12

- month r olling tot a l :

o F PL r e q u e sts t h at m a i n t e n a n c e a n d f ail u r e s be e x c l u d e d f or t h e se m i n or

so u r ce s of GHG e m iss i o n s. T h is is e sp ec ially i m po r ta n t f or c ir cu it b r e ak e rs

u si n g S F 6 wh e re it is di ff

i c u lt if n ot i m

po s sible to d e t e r m i n e loss e s f orm

m a i n t e n a n c e a c ti v iti e s a n d f ail u r e s c o u ld o cc u r.

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 (SF 6 ) limit is rea lly 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 desc ribed in Condition IX.E.7 as BACT for the circuit breakers.

4. E x ce pt du r ing a n e m e r g e n c y

, the The Em e r g e n c y G e n e ra to r s sh a ll be limit e d t o op era tion

of the e n g ine f or m a int e n a n c e a nd t e sting pu rpo s e s as an “ e m e r g e n c y st a tion a r y R I C E” a s

d ef i n e d in 40 P ar t 63 S ubp ar t ZZZ Z

. Annu a l hou r s of op era tion f or Em e r g e n c y

G e n e r a t o r s, f or m a int e n a n ce a n d t e stin g

, sh a ll not e x c ee d 100 24 hou r s p e r 12

- month

r olling tot a l f or e a c h g e n e ra t o r

.

o T h is c o n diti o n is m ore r e stri c ti v e t h an t h e F D E P p e r m i t a n d e sta b lis h e s a l i m i t f or

m ai n t e n a n c e p e r 1 2

- m o n t h roll i n g a ve rag e

. T h is un it is r e g u lat e d un d e r Su bpart IIII

a n d is c l assi f

i e d as an “ E

m e r g e n c y S tatio n ary R I CE ” un d e r Su bpart ZZZZ.

T

h e s e r e g u latio n s h a v e op e rati n g l i mits t h at w o u ld be appli c abl e

. A lso, t h e

t e rm “ e m e rg e n cy ” is n o t d ef

i n e d in E PA P S

D r e g u lati o n s a n d c o u ld be

misi n t e rpr e t e d. T h e 100 h o u rs p e r 12

- m o n th roll i n g a ve rage s h o u ld be t h e

BAC T li m i t as d e t

e r

m i n e d in t h e e m ission li m its i n t h e p e r m i t

. A lso, t h is is

c o n sist en t w ith t h e F D E P p e r m i t.

6. E x ce pt du r ing a n e m e r g e n c y

, the The F i r e P ump En g ine s h a ll be limit e d t o op era tion as

an “e m e r g e n c y st a ti o n a r y R I C E ” a s d ef in e d i n 40 C F R P ar t 63 S ubp a r t ZZZZ of the

e n g ine f or m a int e n a n ce a nd t e sti n g pu rpos e s

. Annu a l hou r s of op e ra t ion f or the F i r e P ump

E n g i n e

, f o r m a int e n a n c e a nd t e stin g

, sh a ll not e x cee d 24 h o u r s p e r 12

- month r olling tot a l.

o S a m e c om m e n t s as t h e e m e rg e n c y g e n e rator22 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. C i rc uit B rea k er s sh a ll be us e d a s e l ec t r i c a l int err u pt er s in the e v e nt of a p o w e r su r g e

, sh a ll be e quipp e d with l o w

- d e nsi t y p re ss u r e a l ar m s

, a nd sh a ll be visu a l l y i n sp ec t e d on a

d a i l y b a sis

. I n a dditi o n, P er mitt e e sh a ll impl e m e nt a m a int e n a n c e p r o g r a m th a t m a int a ins

the int e g r i t y o f the b rea k er s a nd min i mi z e s S F 6 e missions. b rea k er s sh a ll be insp ec t e d

b y the m a n u fac tu r e r on c e e v e r y 5 y ear s, a nd sh a ll be ov e r h a ul e d a t the e nd of th e ir 20

y e a r li f e c y c l e

. R ec o r ds of insp e c tion sh a ll be k e pt in acc o r d a n c e with C ondition I X

. I

. Giv e n th a t this is a wo r k p rac ti c e st a nd ar d, no qu a nti f i ca tion of S F 6 e missions is re qui re d

f

or c ompli a n c e with the B A C T e missions l i mit of 2

. 25 tons p e r y ea r of C O 2 e p e r b r ea k e r

. M a int e n a n c e ac tiviti e s a nd fa ilu res a r e not c o nsid ered in the B A C T e mission limi t

.

o T h e daily i n sp ec tion app e ars unn ece ssary si n c e t h e se br e a k e rs w ill h a v e a

p e r f

or m a n c e sta n dard a n d c h ec k e d on a r e g u lar basis to m ee t r e q u ir e m e n ts of

40 CF R Part 98 Su bpart DD. T h e pri m ary w ay to m e as u re S F 6 is by w e ig h ti n g t h e

e q u ip m en t a n d u s i n g a m ass bal a n c e to d e t e r m i n e e m i ssio n s

. T he p e r f

or m a n c e

sta n dard c it e d in t h e i n f

o r m at i on pro v id e d to E PA w as t h e I n t e r n ati o n al

E l ec trot ec hn i c al C o mmission ( I

E C ) sta n dard of 0.5 p e r c en t ( I

E C S ta n dard 62271

- 1,

20 0 4) t h at is r ec og n iz e d by t h e E PA SF 6 R e d u c tion Part n e rs h ip as an effe c ti v e

c rit e rion f or m i n i m i zi n g f u giti v e S F 6 e missio n s. T h e m a nu f

a c t u r e r i n s p ec tion

eve ry 5 ye ars a n d o ve r h a u l s h o u ld be r e pla ced w ith “p e riodic i n sp ec t i o n s

a cc ordi n g to m a n u f

a c t u r e r r ec om m e n da t io n s”. Pl e ase n ote t h at t h is e q u i p m e n t

is s e al e d. A s d i s c u ss e d pr ev io u sl y

, it is di ff

i c u lt to m e as u re lo s s e s f rom m ai n t e n a n c e

a c ti v it i e s a n d f ai l u r e s c o u ld o cc u r. T h e r ef or e

, n ot i n c l u di n g t h e se as part of t h e

B

A C T l i m its is s u gg e st e d.

EPA Response: EPA agrees that daily inspection of the circuit breakers is unnecessary sin c e 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 manuf acturer’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 remov e the reference to the 2.25 TPY;

however, the commenters request to eliminate maintenance activiti es 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 T e mpo r a r y C onst r u c tion B oil er s s h a ll be l i mit e d to use on l y du r i n g the P r oj ec t

c onst r u c tion p er iod to p r ovide st ea m du r ing c on s t r u c tion ac tiviti e s th a t i n c lud e s but not

limit e d to f or H RS G c l e a ning a nd a sso c i a t e d st ea m blows. Ann u a l hou r s of op era tion f or

e ac h boil e r sh a ll not e x cee d a n a gg r e g a te of 3,000 1,500 h o u r s p e r 12

- month r olling

tot a l. T h e T e mpo r a r y C onst r u c ti o n B oil er s will be p er m a n e nt l y shut down a nd re mo v e d

fr om the fac ili t y o n c e c omm e r c i a l op era tion of t h e P r oj ec t b e g ins.23 o T h e un d e rli n e d t e xt ap p e ars o n ly to apply to t h e H RS G a n d is too r e str i c ti v e as

ot

h e r a c ti v iti e s m ay n ee d st e a m

. S t e am is nee d e d to c l e an st e am t u rbi n e

c o nn ec tio n s a n d a n y w h e re st e am pipi n g is u s e d. S i n c e st e am is u s e d

t h ro u g h o u t t h e 3

- o n 1 c o m bi n e d cyc le un it t h e lo c ation of t h e boil e r is

i m po r ta n t. A boil e r may be c lose to w h e re m ore h o u rs of st e a m is n ee d e d wh i le

t h e ot h e r b o il e r is lo c at e d in a di ffe r e n t ar e a. H a v i n g an i n di v i d

u al h o u r l i m i t

w o u ld r e q u ire pot e n t ial l y m o v i n g a boil e r to c o m pl e te c o n st r u c tio n

. Al so, t h e

F

D E P p e r m i t allo w s a n aggr e gate of 3,000 h o u rs f or t h e t w o boil e rs.

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

environmenta l impacts

. EPA amended Condition IX. E

. 8 to allow this flexibility.

21. Comment:

F . Co n t i nu o u s E m issio n s M o n i t o r i n g S ys te m ( C E M S ) f or C T s

1. At the ear li e st fea sib l e oppo r tuni t y af t e r f i r s t f i r ing of C Ts a nd b ef o r e C Ts

c omm e n c e c omm e rc i a l o p era tion (a s d ef in e d in 4 0 C F R § 72.2 )

, in acc o r d a n c e with

the rec omm e n d a tions of the e quipm e nt m a nu f a c tu r e r a nd the c onst r u c tion c ont rac to r :

a. P er mitt ee sh a ll inst a ll, ca lib ra t e, a nd op e ra te a C EMS f or each C T th at m ea su res

st ac k g a s C O2 c on ce n t ra tions in p ar ts p e r million b y volume ( p pmv )

. The

c on ce nt r a tions sh a ll be c o rrec t e d to 1 5 % O2 on a d r y b a sis. No l a t e r th a n the e nd of

the sh a k e down p e r iod a s d ef in e d in C ondition I X

. J

. or upon c omm e n c ing c omm erc i a l

op era tions, whi c h e v e r c o m e s f i r st, P er mitt e e sh a ll a lso m a int a in, cer ti f y

, a nd qu a li t y

a ssu r e a C EMS f or e ach C T th at m ea su res st ack g as C O2 c o n ce nt r a tions in ppmv,

a nd sh a ll c ondu c t initi a l cer ti f i ca tion of the C EMS in acc o r d a n c e with C onditi o n

I X

. F .6. T h e c on c e nt ra ti o ns sh a ll be c o rr ec t e d to 1 5% O2 on a d r y b a sis.

2. The C O2 C EMS sh a ll m ee t the a ppli ca b l e re qui r e m e nts of 40 C F R P ar t 75.

3. E ac h C EMS sh a ll c o m pl e te a minimum of o ne c y c l e o f op e ra tion ( s a mplin g

,

a n a l y z i n g

, a nd d a ta r e c o r din g ) f o r e a c h su c ce ssive 15

- minute c lo c k

- hour p e r iod.

4. The initi al cer ti f i ca tion of the C EMS m a y e ith e r be c ondu c t ed s e p ara t e l y

, a s sp ec i f i ed

in 40 C F R § 60.334 ( b )( 1 )

, or a s p ar t of the in i ti a l p erf o r m a n c e t e st of ea c h e mission

unit. The C EMS must und e r g o a nd p a ss initi a l p e r f o r m a n c e sp e c i f i ca tion t e sting on or

b ef o r e t h e d a te of t h e initi al p erf o r m a n ce t e st.24 5. The C EMS sh a ll m ee t t h e re qui r e m e nts of 40 CF R § 60.13. D a ta s a mpling, a n a l y z i n g

,

a nd r e c o r di n g s h a ll a lso be a d e qu a te to d e monst r a te c ompli a n c e with e mission limits

du r ing st a r tup a nd shutdown.

6. Not l e ss th a n 90 d a y s p r ior to the d a te of initi a l st ar tup of the fac ili t y

, t h e P er mitt e e

sh a ll submit to the E P A a qu a li t y a ssu r a n c e p r oj ec t pl a n f o r the c er t i f i ca tion a nd

op era tion of the C EM S

. S u c h a p l a n sh a ll c on f o r m to E P A r e qui re m e nts c ont a in e d i n

40 C F R P ar t 60 App e ndix F f or C O2, a nd 40 C F R P ar t 75 App e ndix B f or st ac k f low.

The pl a n sh a ll be upd a t e d a nd r e submitt e d upon re qu e st b y E P A. T h e pl a n sh a ll

sp ec i f y h o w e missions du r ing st ar tups a nd shutdowns will be d e t er min e d a nd

ca l c ul a t e d, in c ludi n g qu a nti f y

i n g f low a cc u r a t e l y i f ca l c ul a tions a r e us e d.

7. The g a s tu r bine C EMS sh a ll be a udit e d qu ar t er l y a nd t e st e d a nnu a l l y in a cc o r d a n c e

with 40 C F R P ar t 60 A p p e ndix F

, P r o ce du r e 1. P er mitt ee sh a ll p erf o r m a f ull st ack

t ra v er se d u r ing initi a l r un of a nnu a l R ATA t e sting of the C EM S

, with t e s ting points

s e l ec t e d a cc o r ding to 40 C F R P ar t 60 App e ndix A, M e thod 1.

8. P er mitt e e sh a ll submit a C EMS p erf o r m a n c e t e st p r oto c ol to the E P A no l a t e r th a n 30

d a y s p r i o r to the t e st d a te to a llow re vi e w of t he t e st pl a n a nd to arr a n g e f or a n

obs er v e r to b e p re s e nt a t the t e st. The p e r f o r m a n c e t e st sh a ll be c ondu c t e d in acc o r d a n c e

with the su b mitt e d p r oto c ol a nd a n y c h a ng e s re qui r e d b y E P A.

9. P er mitt e e sh a ll f u r nish t he E P A a w r itt e n r e po r t of the re sults of p erf o r m a n c e t e sts

within 60 d a y s of c ompl e tion via the c ont ac t in f o r m a tion p r ovid e d in C ondition X.

10. The st ack g as volum e t r i c f low ra t es sh a ll be c a l c ul a t ed in acc o r d a n ce w ith the f u el

f lowm e t e r r e qui re m e nts of 40 C F R P ar t 75 App e ndix D in c ombin a ti o n with the

a pp r op r i a te p ar ts of E P A M e thod 19.

12. P er mitt e e sh a ll m ea su r e a nd r ec o r d, f or e ac h C T, the ac tu a l h ea t in p ut ( B tu) on a n

hou r l y b a sis.

13. P er mitt ee sh a ll m ea s u r e a nd r ec o r d, f or e ac h C T, the f ollowin g :

a . N e t e n e rg y output ( M W hn e t a nd k W hn e t) on a n hou r l y b a sis;

b. P ounds of C O2 p e r n e t e n e rg y output ( lb C O2/M W hn e t) on a n hou r l y b a sis;

c . N e t h e a t ra te ( B tu/kW hn e t) on a n hou r l y b a sis, b a s e d on tot a l h ea t input f or the f a c ili t y ;

d. The t y p e of f u e l ( n a tu r a l g a s or U L S D) b u r n e d on a n hou r l y b a sis;

e

. The 12

- month r olling a v er a ge e mission ra te of lb C O2/M W hn e t a nd B tu/kW hn e t. The25 12

- month r olling a v er a ge sh a ll be b a s e d on the a v er a ge hou r l y r ec o r din g s summ e d f or

each o p e r a ting month a n d a v e r a g e d with the r e sp e c tive ra t e s fr om t h e p r e vious 11 months f or

e a ch f u el t y p e.

• T h e se c o n ditio n s app e a r to be w r i tt e n f or NOx or C O. F or C O 2 CE M, E PA m e t h ods

h a v e alr e ady b ee n e s t ablis h e d t h at c an a cc u rat e ly m e as u re C O 2 e m issi o n s. C O 2

m o n itor i n g h a v e b ee n i m

pl e m e n t e d s i n c e t h e A c id R ain Progr a m a n d F PL o ffe rs t h e

f

ollo w i n g c o n di t io n s d eve lop e d by an e xp e ri e nce d E PA CE Ms e n g i n ee r.

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 CO 2 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 th e 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 CO 2 monitoring being done

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

F . Co n t i nu o u s M o n i t o r i n g of C O 2 f or C T s

1. P er mitt e e sh a ll inst a ll a nd cer ti f y monito r i n g s y st e ms re qui re d f o r qu a nt i f y i n g C O 2

e missions fr om each C T in acc o r d a n ce with the a p pli ca ble re qui r e m e nts of 40 C F R P ar t

75. C onsist e nt with §75

. 4 ( b )

, a ll a ppli ca b l e c e r ti f i ca tion t e sts sh a ll be c o m pl e t e d within

180 ca l e nd a r d a y s a f t er t he d a te the unit c omm e n ces c omm e r c i a l op e r a tion (a s d ef in e d in

40 C F R 72.2 )

.

2. F ollowing initi a l c e r ti f i ca tion, the C O 2 c ontinuous m ea su re m e nt s y st e m s h a ll be

qu a li t y a ssu r e d in a c c o r d a n c e with the a ppli ca ble re qui re m e nts of 40 C F R P ar t 75.

3. The C O 2 c ontinuous m ea su re m e nt s y st e m sh a ll be ca p a ble of p r od u c i n g hou r l y

d e t er min a tions of C O 2 m a ss e missions in tons p e r hour ( tons/h r)

.

4. I n acc o r d a n c e with § 7 5.62, a n initi a l monito r i n g pl a n s h a ll be submitt e d id e nti f y

i n g the

m e thodolo g y f or whi c h C O 2 m a ss e missions wi l l be c ontinuous l y monito r e d. The initi a l

monito r ing pl a n sh a ll be submitt e d no l a t e r th a n 21 d a y s p r ior to the initi a l cer ti f i c a tion t e sts.

5. P er mitt e e sh a ll p r ovide noti f i ca tions a s sp ec i f i e d in §75.61 f or a n y e v e nt re l a t e d to the

c ontinuous m ea su re m e nt of C O 2

.

6. P er mitt e e sh a ll m ea su r e a nd r e c o r d, f o r e ac h C T , the ac tu a l h e a t input ( B t u) on a n

hou r l y b a sis in a cc o r d a n c e with 40 C F R P ar t 75

7 P er mitt e e sh a ll m ea su r e a nd r e c o r d, f o r e ac h C T , the f ollowing on a n ho u r l y b a sis:

a . En e rg y output ra t e ( M W ) ;26 b. C O 2 m a ss e mission ra t e ( tons C O 2 /h r) ;

c . H ea t I nput ra te ( m m B t u/h r) ;

d. Unit Op era ti n g Time a s d e s cr ib e d in §75.57 ( b ) ( 2)

e . The t y pe of f u e l ( n a tu r a l g a s or U L S D) b u r n e d;

8. P er mitt ee sh a ll ca l c u l a te a nd r ec o r d, f or e ac h C T, the f ollowing on a m onth l y b a sis:

a . Month l y a v er a ge C O 2 e mission ra te ( lbs C O 2 / M W h) ca l c ul a t e d a s the s u m of each

hou r l y C O 2 M a ss e mission ra te tim e s the unit op e ra ting time f o r the hour d ivid e d b y the

sum of the rec o r d e d e n e rg y output ra t e s tim e s the unit op era ting time f o r the hour f or a ll

hou r s of op e r a tion in ea c h month. I f mo r e th a n o ne f u e l is utili z e d in a m o nth, a s e p a r a te

a v er a ge C O 2 e missions ra te sh a ll be c a l c ul a t e d f o r eac h f u e l.

b. Month l y a v e r a g e h ea t ra te ( B tu/kW h) ca l c ul a t e d a s the sum of e a c h hou r l y h e a t input

ra te tim e s the unit op era t i ng time f or t h e hour divid e d b y t h e sum of the r ec o r d e d e n e rg y

output ra t e s tim e s the unit op era ting time f or the h our f or a ll hou r s of o p e r a tion in eac h

month tim e s 1,000. I f m o r e th a n one f u el is utili z e d in a month, a s e p a r a te a v er a g e h eat

input ra te sh a ll be c a l c ul a t ed f or e ach f u e l.

9. P er mitt e e sh a ll ca l c u l a te a nd r ec o r d, f or e ac h C T, the f ollowing on a n a nnu a l b a sis:

a . The 12

- month r olling a v er a ge C O 2 e mission ra te ( lbs C O 2 /M W h) (f or e a c h f u e l

c ombust e d in the p re vio u s 12 months) sh a ll be ca l c ul a t e d a s the sum of ea c h month l y

a v er a ge v a lue tim e s the month l y e n e rg y output ( M W h) divid e d b y the s u m of the e n e rg y

output ( M W h) g e n e ra t e d du r ing the 12 month p e r iod.

b. The 12

- month r olling a v er a ge h e a t ra te ( B tu/ k W h) (f or e a c h f u e l c ombust e d in the

p re vious 12 months) sh a ll be ca l c ul a t e d a s the s u m of eac h month l y a v e r a g e h ea t r a te

v a lue tim e se the month l y e n e rg y output ( kW h) divid e d b y the sum of t h e e n e rg y output

( kW h) g e n era t ed du r i n g t he 12 month p er iod.

• T h e last c o n dition r e la t e d to c al c u lati n g t h e 12

- m o n t h roll i n g a ve rage n ee ds to f a c t o r in

t h e a m o un t of g e n e ration prod u ce d e a c h m o n th to d e t e r m i n e c o m p l ia n ce

. T h e c o n dition as

origi n ally w ritt e n u s e s t h e a ve rag e s of m o n th rat e s. T h is c an l e ad to a n e rro n e o u s

c al c u lation w h e re g e n e ration w as ve ry low f or o n e of m ore mo n t h s, c o u pl ed w ith a h igh

lb C O 2 e / M W h r. T h is a ve ragi n g m e t h od w ill a r ti

f

i c ially i n c r e ase t h e 12

- m o n th roll i n g

l b C O 2 e / MWh e m issi o n r a t e

. A c al c u lation is s h o w n b e low u s i n g 100% load f or 10

m o n t h s of op e ration a n d t w o low load c o n ditio n s w i t h h ig h e r GHG e m issi o n rat e s f or

2 m o n t h s of op e ratio n

. T h e e xa m ple c al c u lati o n s are bas e d o n : 1. a w e ig h t e d a ve rage bas e d

on t h e a m o u n t of m o n t h ly g e n e ration ( t h e m o s t a cc u rate d e t e r m i n a tion of a 12

- m o n th

rol l i n g a ve rage e m issi o n rat e)

, a n d 2. an a ve rage o f m o n t h ly a ve rage e m iss i on rat e s. A s

s h o w n

, t h e 12

- m o n t h rol l i n g by a ve ragi n g t h e m o n t h ly lb C O 2 e /M W h i s 770 lb

C O2 e /MW h r w h ile u s i n g a w e ig h t e d a v e rage bas e d on t h e a m o u n t of g e n e ration t h e 12

-27 m o n t h roll i n g a ve rage is 763 lb C O 2 e /MW h

. T h is is abo u t a 1% di f f

e r e n c e a r ti f

i c ially

c r e at e d by t h e a ve ragi n g m e t h od.

E x a mple C a l c ul a tion of Agg r e g a te v er sus Month l y A v er a g e :

Month D a ys lb C O 2 e M W h lb C O 2 e /M W hr

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

S um: 6,585,840,000 8,631,792

Av er a ge

Month l y R a t e s

Adjust e d f or

G e n e r a tion

Amount Av er a ge of

Month l y R a t e s

763 lb

C O 2 e /M W h 770 lb

C O 2 e /M W h28 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 Condition s IX.F. 1

- IX.F. 9

.

22. Comment:

G

. P e r f o r m a n c e T e s t s

1. S t ack T e sts

a

. W ithin 60 d a y s a f t e r ac hi e vi n g no r m a l op e ra tion, but not l a t e r th a n 1 8 0 d a y s

af

t e r the initi a l st ar tup of e quipm e nt, a nd, unl e ss oth er wise sp ec i f i e d, a nnu a l l y

th ere a f t e r ( within 30 d a y s of the initi a l p erf o r m a n c e t e st a nniv er s a r y )

, Pe r mitt e e sh a ll

c ondu c t p erf o r m a n c e t e sts (a s d e s cr ib e d in 4 0 C F R § 60.8) a s f ollow s :

a

.. C O2 e missions fr om e ac h C T

b. P er mitt e e sh a ll subm i t a p erf o r m a n c e t e st p r oto c ol to E P A no l a t e r th a n 3 0 d a y s

p r ior to the t e st to a ll o w re vi e w of the t e st pl a n a nd to arra n g e f or a n Ag e n c y

obs er v e r to be p r e s e nt a t the t e st. The p e r f o r m a n c e t e st sh a ll b e c on d u c t e d in

acc o r d a n c e with the su b mitt e d p r oto c ol, a nd a n y c h a n g e s r e qui re d b y E P A

.

c. P erf o r m a n ce t e sts sh a ll be c ondu c t ed in a c c o r d a n ce with the t e st m e t h ods s e t f o r th

in 40 C F R § 60.8 a nd 40 C F R P ar t 60 A p p e ndix A, a s modi f i e d b e low. I n li e u of

the sp ec i f i e d t e st m e thods, e quiv a l e nt m e thods m a y b e us e d wi t h p r ior w r itt e n

a pp r ov a l f r om E P A:

i. E P A M e thods 1

- 4 a nd 3B f or C O2 e missions, a nd

ii. the p r ovisions of 40 C F R § 60.8 (f)

.

d. Upon w r itt e n re q u e st a nd a d e qu a te justi f i ca tion fr om the P er mitt ee

, E P A m a y

w a ive a sp e c i f ic a nnu a l t e st a nd/or a llow f or t e sting to be done a t l e ss th a n m a x imum

op era ting ca p a c i t y

.

e. F or p erf o r m a n ce t e st pu rpos e s, s a mpling po r t s

, pl a t f o r ms, a nd a c ce ss s h a ll be

p r ovid e d on the e mission unit e x h a ust s y st e m in a cc o r d a n c e with the re qui r e m e nts of

40 C F R § 60.8 (e)

.

f

. P er mitt e e sh a ll f u r nish the E P A a w r itt e n re p o r t of the re sults of p e r f o r m a n c e

t e sts within 60 d a y s of c o mpl e tion to the a dd re ss list e d in C ondition X.

o P e r f

or m a n c e T e sts are unn ece ssary si n c e C O2 e m issi o n s are c o n t i nu o u s ly

m o n itor e d u si n g F e d e r

a l m e t h odolo g i e s ( 40 CF R 75) a n d f or wh i c h t h e data

are e l ec tro n i c ally v alidat e d a n d s u b m itt e d u s i n g E PA r e q u ir e d so f

t w ar e

.

EPA Response: According to Part 75, initial certification of the monitoring system is

required, which i nvolves performance test ing ; therefore, EPA agrees that additional

performance testing is unnecessary. EPA revised the draft p ermit to stipulate that29 certification must be performed in acco rdance to 40 CFR 75 ( see Condition IX.F) and

remove d the requirements of permit Condition IX.G

. [ N ote: Condition IX.G in the final

permit is now a n unrelated compliance condition]

23. Comment:

H. M o n i t o r i n g f or A u x i lia r y Equ i p m e n t

1. P er mitt e e sh a ll inst a ll a nd m a int a in f u e l m ea su r e m e nt e quipm e nt, in c luding but not

limit e d to f u e l t a nk g a g e s a nd f u el r ece ipts, a n op era tion a l non

- re s e tt a b l e tot a li z ing

m a ss or volum e t r ic f low m e t e r to m ea su r e f u e l use in each f u el line f or the 99.8

MM B tu/hr boil e r ( Au x i l i a r y B oil e r)

, the 2,250 kW e m er g e n c y u se e n g i n e s ( Em e r g e n c y

G e n e ra to r s )

, a nd the 300 hp e m er g e n c y

- use f i r e w a t e r pump (F i r e P ump En g in e s )

, to F u el

use sh a ll be rec o r d e d monthly a nd tot a l e d e v e r y month f or the p re vious 12 months.

o M u c h of t h is e q u i p m e n t h as n o t b ee n p u r ch as e d a n d t h e re are nu m e ro u s

m e t h ods to m e as u re f u e l u se i n c l u d i n g m ai n tai n i n g f u e l r ec ords f or ta n ks. F or

e

xa m pl e

, t h e di e s e l e n gi n e s t y

pi c ally h a v e a d e di c at e d ta n k wh e re

m e as u r e m e n ts c an be obtai n e d. Gi ve n t h e mi n or e m is s io n s a n d l i m it e d

op e ration of t h e se u n its h a v i n g a f u e l f l o w m e t e r w ith r ec ordi n g is u n n ece ssary to

d

e m o n s trate c o m p lia nc e w ith t h e BAC T l i m it.

3. P er mitt e e sh a ll inst a ll a nd m a int a in a l ea k d e t e c tion s y st e m on the c i rc u it b rea k er s t h a t

si g n a ls an a l a r m in the f ac ili t y ’ s c ont r ol r oom in the e v e nt th a t a n y c i rc u i t b rea k e r los e s

mo r e th a n 10% of its di e l ec t r ic f luid. The ow n er / op era tor sh a ll p r ompt l y r e spond to a n y

a l ar m, inv e stig a te the c i r c uit b rea k e r involv e d, a nd f ix a n y l ea k

- t i g htn e ss p r obl e ms th at

ca us ed the a l ar m

.

o T h is c o n diti o n is u n n ece ssary w ith t h e r e q u i r

e m e n ts of C o n di t ion E

. 7. T h e

br e ak e rs are s e al e d e q u ip m en t a n d w ith r e g u l a r i n sp ec tio n s pro v ide a s s u ra n c e t h at

SF 6 e missio n s are l i m i t e d.

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 SF 6 BACT limit

is a work practice standard. See EPA’s response to comment 20 for more discussion on SF 6

. The p ermit 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. R ec o r dk ee p i n g a n d R e p o rt i ng

6. A p er iod of monitor down

- time sh a ll be a ny unit op era ti n g c lo c k hour in whi c h

su ff i c i e nt d a ta a r e not obt a in e d b y the C EMS to v a lid a te the hour f or C O2 acc o r di n g to

40 C F R P ar t 75

.30 o Su gg e st d e f i n i n g m o n i t o r

- d o w n t i m e a cc o r d i n g t o an e xis t i n g re g u la t o r y

re qu i r e m e n t

.

EPA Response: EPA agrees with this assessment. EPA revised t his condition to reference 40

CFR 75. See Condition IX.I.6

.

25. Comment:

J. Sh a k e d o w n P er io ds

The c ombustion tu r bine a nd a u x i li a r y e quipm e nt e mission lim i ts a nd re qui re m e nts in

C onditions I X. C

, I X.D, a nd I X.E s h a ll not a pp l y du r ing c ombustion sh a k e down p er io d s

f

or the c ommissioning o f the 3

- on

- 1 c ombin e d c y c l e unit

. S h a k e down is d ef in e d a s the

p er iod b e g inni n g with i n iti a l st ar tup a nd e ndi n g n o l a t e r t h a n initi a l p e r f o r m a n c e t e stin g

, du r ing wh i c h the P er mitt e e c ondu c ts op e ra tion a l a nd c ont r a c tu a l t e sting a nd tuning to

e nsu r e t h e s a fe

, e f f i c i e nt a nd re li a ble op e r a tion o f the p l a nt. The sh a k e d o wn p er iod sh a ll

not e x cee d 90 180 d a y s f or e ach f u e l

. W ith the e x ce ption of C onditions I X

. C

. D a nd E

du r ing sh a k e down p e r iods

. T T he re qui r e m e nts of S ec tion I I I of this p er m i t sh a ll a pp l y a t

a ll tim e s.

o T h e 3

- o n

- 1 c o m bi n e d cyc le un it r e q u ir e s i n t e gration of e a c h C T/H R S G train

w ith t h e st e a m t u rb i ne

. T h is t y

pi c ally i n v o l ve s op e ration of t h e C T a n d

c o m b u s t ion t un i n g pri o r to t y i n g i n to t h e st e a m t u rb i n e

. In additi o n

, e a c h f u e l

w ill n ee d s e parate c o mm i ssio n i n g p e riods as t h e ir c o m b u s tion pro ce ss e s are

q u ite di ffe r e n t. T h e la s t s e n t e n c e app e ars to c o n tradi c t t h e f irst s en t ence

. T h is

p h rase w as add e d f or c lari f

i c atio n

.

EPA Response: EPA agrees with th e 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

. G lo b al Wa r m i n g P o t e n t ial ( G W P )

F or the pu rpos e s of sho w ing c ompli a n c e with a n y GHG e mission lim i t in t his p er mit, the

G W P fac to r s list e d in 40 C F R P ar t 98 S ubp ar t A, T a ble A

- 1 a s o f the d a te of this p er mit

sh a ll be us e d. The GHG e mission l i mits f or C T s /H RS Gs w er e d e v e lop e d using 40 C F R

P ar t 98 S ubp ar t C e miss i ons fac to r s ( T a bl e s C

- 1 a nd C

- 2 )

. The GHG e mission limits f or

the C Ts/H RS Gs m a y be a djust e d a f t e r a g e n c y re vi e w if the ac tu a l e missions in

lb C O2/MM B tu d e t er mi n e d fr om the C EMs a nd f u e l s a mpling ar e hi g h e r t h a n those us e d

as a b a sis of this p er mit. The c u r r e nt G W P a nd e mission fac to r s ar e list e d b e low:

GHG

P o ll u ta n t G WP F a c t o r E m i ss i on

F a c t o r

( k g C O 2 /M

M Bt u )

C O 2 1 53.02

C H 4 21 0.001

N 2 O 310 0.0001

S F 6 23,900o T h e u se of t h e 40 CF R Part 98 e mission f a c tors c o u ld be di ffe r e n t t h an t h e

e m issi o n s t h at a c t u ally o cc u r u si n g pip e li n e n at u ral gas in t h e C Ts / H

RS Gs.

F

PL r e li e s on s e ve ral s o u r ce s of n at u ral gas a n d di ffe r e nc e s m ay o c cu r. F PL

r e q u e sts t h at t h is c o n dition i n c l u de t h e poss i bility of an adj u st m e n t to t h e

lb C O 2 /M W h e m i s sion l i m i t a f

t e r ag e n c y r ev i e w t h at w o u ld be bas e d on a c t u al

data d u ri n g op e rati o n

.

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 chang es have not been finalized.

Consequently, this condition was added to the permit solely to e nsure the correct GWP

factors a re used for determining future compliance with the CO 2 e 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.