EFS Shady Hills LLC Project (PSD-EPA-R4013) – Final Determination 1/13/2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4

Final Determination

Prevention of Significant Deterioration Air Permit PSD-EPA-R4013

EFS Shady Hills Generating Station Project

January 13, 2014

On September 24, 2013, the Region 4 office of the U.S. Environmental Protection Agency (EPA)

requested public comment on a draft Prevention of Significant Deterioration (PSD) air permit for 

Greenhouse Gas (GHG) emissions from EFS Shady Hills LLC’s (Shady Hills) Generating Station

Project (Project).

This Project is proposing to build two additional simple cycle combustion turbines (Model: General 

Electric 7FA.05) at their existing facility. The GE7FA.05 output is 218 megawatts (MW) (gross) when 

firing natural gas and 223 MW (gross) when firing ultra-low sulfur distillate (ULSD) fuel oil. The 

primary fuel will be natural gas with ULSD fuel oil, with sulfur content of is 0.015 percent, as backup 

fuel. The heat input per turbine would be 2,135 million British thermal units per hour (MMBtu/hour), 

high heating value (HHV) at 59 deg. F, 60 percent relative humidity (ISO conditions). Ancillary 

equipment consists of a 2.5 MW emergency generator (EU 007), a natural gas fuel heater (EU 008), a 

2.8 million gallon (Mgal) ULSD fuel oil storage tank (EU 009), SF6 circuit breakers (EU 010), and new 

on-site natural gas pipeline.

The EPA prepared a preliminary determination, fact sheet, and statement of basis document that 

explains the permit requirements. These documents, as well as the application, supporting materials, 

public notice and response to public comments are available in the Administrative Record for this 

project. The Administrative Record is available at the EPA Region 4 office and can be accessed through 

EPA’s website at: http://www.epa.gov/region4/air/permits/ghgpermits/shadyhills_ghg.html and

www.regulations.gov (Docket #EPA-R04-OAR-2013-0647).

The EPA announced the public comment period and opportunity for public hearing via a public notice 

published in The Tampa Tribune, in emails to the GHG public notice list, and on www.regulations.gov

and the EPA Region 4’s website. A total of 60 comments from two commenters were received (via 

email and the regulations.com site) during the public comment period, which closed on 

October 24, 2013. The EPA reviewed each of the comments received and prepared a Response to 

Comments document, which summarizes the comments and provides the EPA’s responses. Complete 

copies of all comments are included in the Administrative Record for the Project, which can be accessed

at the websites listed above. 

After consideration of the expressed view of all interested persons, the pertinent federal statutes and 

regulations, the application and supplemental information submitted by the applicant, and additional 

material relevant to the application and contained in the Administrative Record, the EPA has made a 

final determination in accordance with title 40, Code of Federal Regulations (CFR), part 52, to issue 

PSD air permit PSD-EPA-R4013 to Shady Hills.
EFS Shady Hills LLC Project (PSD-EPA-R4013) – Final Determination 1/13/2013

The final permit differs from the draft permit offered for public comment and the changes are indentified 

in the redline-strikeout version of the final permit. In summary, the EPA made the following changes to 

the draft permit as a result of our response to public comments:

1. Corrected a number of typos including, but not limited to, incorrect company name and location; 

deleted reference to GHG pollution control equipment; added reference to International Standard 

Organization (ISO) conditions.

2. Clarified that the GHG BACT limits for EU 005 and 006 in Condition IX.B.1 applied at all times 

except for startup and shutdown.

3. Clarified various inspection frequencies, monitoring, and recordkeeping and reporting 

requirements specified in Sections IX.B. through G.

4. Added Condition IX.C.3. regarding startup and shutdown hours.

5. Due to the new Global Warming Potential factors that became effective January 1, 2014, the 

GHG limit (as CO2e) changed from 3,965 TPY to 3,966 TPY. Also, Condition J was revised to 

incorporate the new GWP values.

6. Clarified the operation of the EU 007 Emergency Generator to allow operation for maintenance 

and testing, emergency demand response, voltage deviations, and non-emergency purposes as 

defined in 40 CFR 63 Subpart ZZZZ. (Condition IX.D.3.)

7. Added a limit from the regulation regarding the total hours allowed for non-emergency 

situations. (Condition IX.D.3.)

8. Other changes for clarification purposes not requested by the commenters, such as:

a. Added a note in Condition IX.B.3.

b. Revised the definition of startup and shutdown (Conditions IX.C.1 and 2.)

c. Added a requirement to repair leaks immediately for EU 010 and the on-site pipeline and 

natural gas supply (Conditions IX.D.4. and 5.)

d. Updated the value of the Global Warming Potential factors (Condition J)

The final permit, EPA’s response to the public comments, and additional supporting information are 

available at http://www.epa.gov/region4/air/permits/ghgpermits/shadyhills_ghg.html, as well as, the 

EPA Region 4 Office and are also available upon request to Ms. Rosa Yarbrough at: 

R4GHGpermits@epa.gov; (404) 562-9643; or in writing to: EPA Region 4, APTMD; ATTN: Ms. Rosa 

Yarbrough; 61 Forsyth Street, SW; Atlanta, GA 30303.

Any person who filed comments on the draft permit may petition the Environmental Appeals Board

(EAB) to review any of the revised conditions of the final permit, including a showing that the 

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

demonstration that these same issues were raised during the comment period. Please see 40 CFR § 

124.19 and visit http://www.epa.gov/eab/ for more information regarding the procedure for appeals to 

the EAB.