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## ***PUBLIC NOTICE COPY***

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 4 Atlanta, Georgia

Prevention of Significant Deterioration Permit

For Greenhouse Gas Emissions

Permit PSD

- EPA

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In accordance with the provisions of the Clean Air Act (CAA), Subchapter I, Part C

, 42 U.S.C. § 7 4 7 0

, the implementing Prevention of Significant Deterioration (PSD) of Air Quality Regulations at the Code of Federal Regulations (CFR) Title 40 , Section 52.21 (40 CFR § 52.21 )

, and the Federal Implementatio n Plan (FIP) at 40 CFR § 52.37 [effective

December 30, 2010, and published at 75 FR 82246 (Dec. 30, 2010)], the U

. S

. Environmental Protection Agency Region 4 hereby authorizes :

New Hope Power Company (NHPC) Okeelanta Cogeneration Plant 8001 U.S. Highway 27 South South Bay, Florida 33493

to construct and operate Greenhouse Gas (GHG) air emissions units as a modification to the existing Okeelanta Cogeneration Plant located at 8001 U.S. Highway 27 South, South Bay ( Palm

Beach County), Florida.

T his modification to the Okeelanta Cogeneration Plant shall be constructed and operated in accordance with the terms and conditions set forth in this permit.

This p ermit becomes effective on [ INSERT EFFECTIVE DATE]

.

This permit addresses GHG

- related PSD requi rements only. For this Project, the State of Florida, through the Florida Department of Environmental Protection (FDEP) , retains jurisdiction over PSD permitting for regulated pollutants other than GHGs. This permit shall not relieve the owner

or operator of the responsi bility to comply fully with all applicable provisions of federal and state

law.

__________ ______________________ Date Signed Jeaneanne M. Gettle Beverly H. Banister Acting Director Air, Pesticides, and Toxics Management DivisionPSD

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AUTHORITY

The EPA issues this permit pursuant to Subchapter I, Part C, of the Clean Air Act (CAA), 42 U.S.C. § 7470, the implementing PSD Regulations at 40 CFR § 52.21 , and the FIP at

40 CFR § 52.37 [effective December 30, 2010 and published at 75 FR 82246 (Dec. 30, 2010)]

. This permit is based upon application materials submitted to the EPA by New Hope Power Company ( N HPC ), dated February 4, 2013 ; May 17

, 2013; and November 11

, 2013; supplemental submittals in the administrative record for this permit action, and upon the technical analysis performed by the EPA.

APPLICANT

New Hope Power Company Okeelanta Cogeneration Plant 8001 U.S. Highway 27 South South Bay, Florida 33493

PROJECT LOCATION

NHPC ’s project will be located at the existing Okeelanta Cogeneration Plant located at 8001 U.S. Highway 27 South, approximately 6 miles south of the city of South Bay ( Palm Beach County), Florida.

PROJECT DESCRIPTION

NHPC has applied for a Prevention of Significant Deterioration (PSD) air permit for the emission of Greenhouse Gases (GHGs) pursuant to the Clean Air Act (CAA) from the United

States Environmental Protecti on Agency (EPA) Region 4 for a proposed project (Projec t) at the

Okeelanta Cogeneration Station (Okeelanta) . NHPC is proposing to build one natural

- gas

- fired

boiler (Boiler D) to be used primarily for steam at their existing 140

- megawatt (MW) net electric cogeneration facility

. Th e facility currently operates two three cogeneration boilers that combust primarily biomass (bagasse and wood) to generate steam and electricity (Boilers A, B and C)

. , and one Boiler A can also fire natural gas and fuel oil

. boiler to generate steam and electricity (Boilers A, B and C ). The primary fuel for Boiler D will be natural gas, with very low sulfur

distilla te fuel oil (fuel oil) used as backup.

Th is PSD permit for the Project requires the use of Best Available Control Technology (BACT)

to limit emissions of GHG s to the greatest extent feasible

.

EQUIPMENT LIST

The following devices and activities are subject to this PSD permit:PSD

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Unit ID Description

Natural Gas

Fired Boiler  M aximum 1

- hour combined heat input rate of 589 million British

thermal units per hour ( MMBtu/hr ) (H igher H eating V alue )

 Maximum 1

- hour steam production rate of 440,000 lb/hr

 Use of e conomizer and a ir pre

- heater

PERMIT CONDITIONS

I. PERMIT EXPIRATION

As provided in 40 CFR § 52.21(r), this PSD p ermit shall become invalid if construction:

A. is not commenced [ as defined in 40 CFR § 52.21(b)(9 ) ] within 18 months after the approval takes effect; or

B. is discontinued for a period of 18 months or more; or

C. is not completed within a reasonable time

.

II. PERMIT NOTIFICATION REQUIREMENTS

Pursuant to Condition IX : SPECIAL CONDITIONS

, Permittee shall notify the EPA Region 4 of the:

A. date construction is commenced, postmarked within 30 days of such date;

B. actual date of initial setting in operation for any purpose

, postmarked within 15 days of such date; and

C

. date upon which initial certification tests will commence

, in accordance with the provisions of Condition IX. D , postmarked not less than 21 days prior to such date

. Notification may be provided with the submi ttal of the certification test protocol required pursuant to Condition I X. D

.

III. FACILITY OPERATION

A. At all times, including periods of startup, shutdown, and malfunction, Permittee shall, to the extent practicable, maintain and operate the facility in a manner consistent with good air pollution control practice for minimizing emissions

. Determination of whether acceptable operating and maintenance procedures are being used will be

based on information available to the EPA, which may include, but is not limited to, monitoring results, review of operating maintenance procedures and inspection of the facility

.PSD

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B. The Permittee shall operate and maintain the boiler and associated components in a manner consistent with good engineering practices for its full utilization.

C. As soon as practicable f ollowing initial startup of the boiler (as defined in

40 CFR § 60.2) but prior to commencement of commercial operation, and thereafter, the Permittee shall develop and implement an operation and maintenance plan for th e facility , consistent with Condition III.B above

. At a minimum, the plan shall identify measures for assessing th e performance of the f acility , the acceptable range of the plant performance measures for achieving the design steam output, the methods for

m onitoring the plant performance measures, and the routine pr ocedures for maintaining the f

acility in good operating condition.

IV. MALFUNCTION REPORTIN G

A. Permittee shall notify the EPA Region 4 via the contact information provided in

Condition X : A GENCY NOTIFICATIONS within two (2) calendar days following the discovery of any failure of process equipment, or failure of a process to operate in a normal manner, which results in an increase in emissions above the allowable

emission limits stated in Condition I X of this permit.

B. In addition, pursuant to Condition X: A GENCY NOTIFICATIONS

, Permit tee shall provide written notification to the EPA within fifteen (15) calendar days of any such

failure described under Condition IV.A above

. This notification shall include a description of the malfunctioning equipment or abnormal operation, the date of the initial malfunction, the period of time over which emissions were increased due to the failure, the cause of the failure, the estimated res ultant emissions in excess of those

allowed in Condition I X : SPECIAL CONDITIONS , and the methods utilized to mitigate emissions and restore normal operations

.

C. Compliance with this malfunction notification provision shall not excuse or otherwise

consti tute a defense to any violation of this permit or any law or regulation such malfunction may cause.

V. RIGHT OF ENTRY

The EPA Regional Administrator, and/or an authorized representative, upon the presentation of credentials, shall be permitted:

A. t o enter the premises where the f acility is located or where any records are required to be kept under the terms and conditions of this PSD p ermit;

B. during normal business hours, to have access to and to copy any records required to be kept under the term s and conditions of this PSD p ermit;PSD

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C. to inspect any equipment, operation, or method subject to requirements in this PSD

p ermit; and

D. to sample materials and emissions from the source(s).

VI. TRANSFER OF OWNERSHI P

In the event of any changes in control or ownership of the f acility, this PSD p ermit shall be binding on all subsequent owners and operators

. Within 14 days of any such change in control or ownership, Permittee shall notify the succeeding owner and operator of the

existence of this PSD p ermit and its conditions by letter

. Permittee shall send a copy of

this letter pursuant to Condition X: A GENCY NOTIFICATIONS to the EPA Region 4 within thirty (30) days of its issuance

.

VII. SEVERABILITY

The provisions of this PSD p ermit are severable, and, if any provision of the PSD p ermit is held invalid, the remainder of this PSD p ermit shall not be affected.

VIII. ADHERENCE TO APPLICA TION AND COMPLIANCE WITH OTHER

ENVIRONMENTAL LAWS

A. Permittee shall construct th e P roject in co mpliance with this PSD permit, the application on which this permit is based

, and all other applicable federal, state, and local air quality regulations. This PSD permit does not release the Permittee from any liability for compliance with other applicable federal, state and local environmental laws and regulations, including the Clean Air Act.

B. If prehistoric or historic artifacts, such as pottery or ceramics, stone tools or metal implements, or any other physical remains that could be associated with Native American cultures, or early colonial or America settlement are encountered at any

time wi thin the project site area, the permitted project should cease all activities involving subsurface disturbance in the immediate vicinity o f such discoveries. Upon such discovery, P ermittee, or other designee, shall contact the Florida Department of State, Division of Historical Resources, Review and Compliance Section at 850.245.6333 or 800.847.7278, as well as the appropriate permitting agency office ( FDEP and the EPA Region 4) . Project activities shall not resume without verbal

and/or written authorization from the Division of Historical Resource. In the event that unmarked human remains are encountered during permitted activities, all work shall stop immediately and the proper authorities notified in a ccordance with Section 872.05, Florida Statutes.PSD

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### I X. SPECIAL CONDITIONS

A. Air Pollution Control Equipment and Operation

Permittee shall perform any necessary operations to minimize emissions so that emissions

are at or below the emission limits specified in this permit

.

B. Boiler Emission and Operational Limits and Work Practices

1. For maximized efficiency , the Permittee shall maintain e fficient burner design and optimization, capture of energy from boiler blowdown , insulate the unit, and utilize instrumentation/controls to achieve high

- efficiency/low

- emissions perf ormance including but not limited to practices a s described in the application.

2. At all times, Permittee shall not discharge

, or cause the disc harge of

, emissions from the

boiler into the atmosphere in excess of the following:

Operating Scenario GHG E mission Limit 1
( on gross output basis )

Natural Gas 157 pounds ( lb ) of carbon dioxide equivalent (C O 2 e ) per 1,000 lbs steam produced ( 30

- day rolling average )

Fuel Oil 218 lb C O 2 e per 1,000 lbs of steam produced

( 3

- hour rolling average)

1 Compliance with the above limits shall be demonstrated in accordance with Condition IX. C

. 3

.

3. Except for periods of natural gas curtailment or supply interruption (as defined at 40 CFR 63.7575)

, boiler shall be limited to operating no more than 48 hours per 12

- month rolling period when burning fuel oil

. Permitte e shall monitor and record hours burning fuel oil monthly and totalled every month for the previous 12 months.

4. The boiler shall maintain a heat conversion rate of heat input to usable steam of at least

85% (thermal efficiency) in any month, on a 30

- day rolling average.

C. Monitoring for Boiler

1. Permittee shall record, for the boiler , the following on an hourly basis:

a. Heat input rate (MMBtu );

b. S team output rate (1,000 lbs );

c. Unit operating time;PSD

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d. The t ype of fuel and amount of fuel (natural gas or fuel oil) burned.

2. Permittee shall c alculate and record, for the boiler :

a. On a daily basis, a 30 day rolling average C O 2 e emission rate, as described in

Condition IX.C.3

, (lb s C O 2 e / 1,000 lb s Steam ) calculated as the sum of each hourly

C O 2 e emission rate times the unit operating time for the hour divi ded by the sum of

the recorded steam output rates times the unit operating time for the hour for all hours of operation in each day averaged for the previous 30 days , while burning natural gas

.

b. On an hourly basis, a 3

- hour rolling average CO 2 e emission rate, as described in

Condition IX.C.3

, (lbs CO 2 e /1,000 lbs Steam) calculated as the sum of each hourly

CO 2 e emission rate times the unit operating time for the hour divided by the sum of the recorded steam output rates times the unit operating time for the hour for all hours of operation in each hour averaged for the previous 3 hours, while burning fuel oil.

c. On a daily basis, a 30 day rolling average conversion rate of h ea t in put to steam produced , as described in Condition IX.B.4, calculated as the heat input rate t i m im es the unit operating time for the hour divided by the s um o f the recorded useful steam output rates times the unit operating time for the hour for all hours of operation in day, averaged for the previous 30 days

.

3

. For demonstrating compliance with the limits specified in Condition IX.B. 2 , Permittee shall use the procedures set forth in 40 CFR part 98 to determine resulting GHG emissions (as CO 2 e) based on the combination of calculated CO 2 emissions and

calculated CO 2 e of other GHG pollutants [ as specified in Condition E : GLOBAL WARMING POTENTIAL (GWP ) ]

. Permittee shall keep adequate records of these GHG emission calculations according to requirements in Condition IX.D .1 , on a daily basis

.

D. Recordkeeping and Reporting

1. Permittee shall maintain a file of all records, data, measurements, reports, and documents

r elated to the operation of the f acility, including, but not limited to, the following:

a. A ll records or reports pertaining to adjustments and/or maintenance performed on any system or device at the f

acility pertaining to GHG emissions ;

b. A ll other information that this permit requires the Permittee to obtain, maintain, or develop, recorded in a permanent form suitable for inspection

.

2. Permittee shall maintain monitoring system records that include the following: the

occurrence and duration of a ny startup, shutdown, malfunction, performance testing, evaluations, calibrations, checks, adjustments, maintenance, duration of any pe riods during which monitoring data is unavailable , and corresponding emission measurements

.

3. Permittee shall maintain records of all source tests and monitoring and compliancePSD

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information required by this permit

.

Permittee shall maintain records and submit a written report of all deviations from permit requirements to the EPA semi

- annually, except when: more frequent reporting is specifically required by an applicable subpart; or the Administrator, on a case

- by

- cas e basis, determines that more frequent reporting is necessary to accurately assess the compliance status of the source

. The report is due on September 30 th and March 31 st and shall include the following:

a. If applicable, t ime intervals, data and magnitude o f the excess emissions, the nature and cause (if known), corrective actions taken and preventive measures adopted ;

b. If a pplicable

, the time and date of each period during which the monitoring data

was unavailable (monitor ing down

- time), except for zero and span checks, and the

nature of monitoring system repairs or adjustments;

c. A statement in the report of a negative declaration; that is, a statement when no

excess emissions occurred or when the monitoring system has not been inoperative, repaired, or adjusted;

d. Any failure to conduct any required source testing, monitoring, or other compliance activities; and

e. Any violation of limitations on operation, including but not limited to restrictions on hours of operati on.

5. Excess emissions shall be defi ned as any period in which the f acility emissions exceed the maximum emission limits set forth in this permit.

6. A period of monitor ing down

- time shall be any unit operating clock hour in which

sufficient data are not obta ined by the monitoring methods to validate the hour for C O 2 e

.

7. Excess emissions indicated by the monitoring , source testing, or compliance monitoring shall be considered violations of the applicable emission limit for the purpose of this permit.

8. Permittee shall maintain a copy of the current operation and maintenance plan for the

f acility , and shall keep a copy of all prior versions of the plan for a minimum of five

years

. Permittee shall also keep records of the monitoring data for each of the f a cility performance measures and all maintenance activities; the Permittee shall maintain such records for a minimum of five years following the date they are created

9. Unless otherwise specified herein , a ll records required by this PSD p ermit shall be

retained for not less than five (5) years following the date of such measurements, maintenance, reports , and/or records. These records shall be made available for reviewPSD

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upon request by the Agency or authorized representative during the cour se of an inspection.

E. Global Warming Potential (GWP)

For the purposes of showing compliance with any GHG emission limit in this permit, the

GWP factors listed in 40 CFR p art 98

, s ubpart A, Table A

- 1 as of the date of this permit

shall be used. The curren t GWP factors are listed below :

GHG Pollutant GWP Factor

CO 2 1

CH 4 2 5

N 2 O 298

X. A GENCY NOTIFICATIONS

All notifications, reporting or other communications relating to this permit shall be

submitted to:

Chief

Air & EPCRA Enforcement Branch Air, Pesticides and Toxics Management Division U.S. EPA Region 4 61 Forsyth Street, SW Atlanta, GA 30303

In addition, electronic copies of the above

- referenced notifications and communications shall be submitted to the following individuals at their corresponding email address:

Name Email Phone

Jason Dressler dressler.jason@epa.gov 404

- 562

- 9208 Katy R. Lusky forney.kathleen@epa.gov 404

- 562

- 9 130

Heather Ceron ceron.heather@epa.gov 404

- 562

- 9185