PSD-EPA-R4013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region 4 

Atlanta, Georgia 

Preliminary Determination & Statement of Basis

Shady Hills Generating Station Project

for

Shady Hills Power Company, LLC

September XX, 2013
PSD-EPA-R4013

Table of Contents

Table of Contents........................................................................................................................................ 1

1.0 Introduction........................................................................................................................................... 3

2.0 Applicant Information........................................................................................................................... 4

2.1 Applicant Name and Mailing Address.............................................................................................. 4

2.2 Facility Location ............................................................................................................................... 4

3.0 Proposed Project ................................................................................................................................... 5

4.0 Legal Authority and Regulatory Applicability ..................................................................................... 7

4.1 EPA Jurisdiction ............................................................................................................................... 7

4.2 Prevention of Significant Deterioration (PSD)................................................................................. 7

4.3 Title V............................................................................................................................................... 8

4.4 New Source Performance Standards (NSPS) ................................................................................... 8

5.0 Project Emissions.................................................................................................................................. 9

5.1 Emission Unit Analysis .................................................................................................................. 10

EU 005 and 006 – Two 223 MW GE7FA.05 SCCTs....................................................................... 10

EU 007- 2,500 kW Emergency Generator........................................................................................ 11

EU 008- 10 MMBtu/hr Natural Gas Heater...................................................................................... 11

EU 009- 2.8 Mgal ULSD Fuel Oil Storage Tank ............................................................................. 11

EU 010 – Circuit Breakers................................................................................................................ 11

Fugitives – On-Site Pipeline and Natural Gas Supply...................................................................... 11

5.2 Compliance Methodology (Monitoring, Recordkeeping, and Reporting)...................................... 11

6.0 Best Available Control Technology (BACT) and Recordkeeping Requirements.............................. 12

6.1 GHG BACT Analysis for two 223 MW GE7FA.05 SCCTs ..................................................... 13

Step 1: Identify all available control technologies............................................................................ 13

Step 2: Eliminate technically infeasible control options................................................................... 14

Step 3: Rank remaining control technologies................................................................................... 16

Step 4: Economic, Energy, and Environmental Impacts .................................................................. 16

Step 5: Selection of BACT ............................................................................................................... 18

6.2 GHG BACT Analysis for Smaller Combustion Equipment: Emergency Generator (EU 007) 

and Natural Gas Fuel Heater (EU 008)................................................................................................. 19

Step 1 & Step 2: Identify all available control technologies and eliminate technically infeasible 

control options .................................................................................................................................. 19

Step 3 & 4: Rank remaining control technologies and evaluation of impacts.................................. 21

Step 5: Select BACT......................................................................................................................... 21

6.3 GHG BACT Analysis for Circuit Breakers.................................................................................... 21

Step 1: Identify all available control technologies............................................................................ 21

Step 2: Eliminate technically infeasible control options................................................................... 22

Step 3 & 4: Rank remaining control technologies and evaluation of impacts.................................. 22

Step 5: Select BACT......................................................................................................................... 22

6.4 GHG BACT Analysis for GHG Fugitive Emissions from On-Site Pipeline.................................. 22

Step 1: Identify all available control technologies............................................................................ 22

Step 2: Eliminate technically infeasible control options................................................................... 22

Step 3 & 4: Rank remaining control technologies and evaluation of impacts.................................. 23

Step 5: Select BACT......................................................................................................................... 23

7.0 Additional Requirements.................................................................................................................... 24

7.1 Endangered Species Act ................................................................................................................. 24

7.2 Essential Fish Habitat of Magnuson-Stevens Act........................................................................... 24
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7.3 National Historic Preservation Act ................................................................................................. 24

7.4 Coastal Zone Management Act....................................................................................................... 25

7.5 Executive Order 12898 - Environmental Justice ............................................................................ 25

7.6 Executive Order 13175 – Tribal Consultation................................................................................ 26

8.0 Public Participation............................................................................................................................. 27

8.1 Opportunity for Public Comment ................................................................................................... 27

8.2 Public Hearing ................................................................................................................................ 27

8.3 Administrative Record.................................................................................................................... 28

8.4 Final Determination ........................................................................................................................ 28
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1.0 Introduction

Shady Hills Power Company, LLC (the Applicant or Shady Hills) 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 U.S. Environmental Protection Agency Region 4 for the proposed Shady 

Hills Generating Station Project (SHGS or Project). Shady Hills is proposing to build two additional, 

simple cycle combustion turbines (Model: GE 7FA.05). The GE7FA.05 output is 218 megawatts (MW) 

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

SHGS will result in an increase of 69 tons per year (TPY) of total suspended particles (TSP)/particulate 

matter with an aerodynamic diameter equal to or less than ten microns (PM10)/particulate matter with an 

aerodynamic diameter equal to or less than 2.5 microns (PM2.5), 397 TPY of nitrogen oxides (NOx), and 

923,502 TPY of GHG emissions. The existing facility and proposed SHGS is located within the City of 

Spring Hill, in Pasco County, Florida. The Standard Industrial Classification No. for this facility is 4911 

Electric Services.

The EPA Region 4 is the agency responsible for implementing and enforcing PSD requirements for 

GHG sources in Florida. The State of Florida, through the Florida Department of Environmental 

Protection (FDEP), implements and enforces PSD requirements for regulated pollutants other than 

GHGs. The EPA has completed review of the application and supplemental materials and is proposing 

to issue Permit No. PSD-EPA-R4013 to Shady Hills for the Project subject to the terms and conditions 

described in the permit. The draft permit incorporates the applicable requirements for GHGs from the 

federal PSD program.

This document serves as a fact sheet, preliminary determination, and statement of basis for the draft 

permit. It provides an overview of the project, a summary of the applicable requirements, the legal and 

factual basis for the draft permit conditions, and the EPA’s analysis of key aspects of the application and 

permit such as the best available control technology (BACT) analysis for GHG emissions. Additional 

information can be found in the draft permit accompanying this document as well as in the application 

materials and administrative record for this project, as discussed in Section 8.0.1

Section 2.0 provides applicant and facility information followed by a description of the proposed project 

in Section 3.0. Section 4.0 lists the legal authority and regulatory applicability. Pollutants emitted and 

emissions units are discussed in Section 5.0. The BACT for all applicable units is listed in Section 6.0. 

Section 7.0 includes a description of additional requirements and how this project complied with them. 

Finally, Section 8.0 gives information about public participation.

 

1 The procedures governing the issuance of PSD permits are set forth at 40 CFR part 124, subparts A and C. See 40 CFR §§ 52.21(q) and 

124.1. Accordingly, EPA has followed the procedures of 40 CFR part 124 in issuing this draft permit. This Preliminary Determination

describes the derivation of the permit conditions and the reasons for them as provided in 40 CFR § 124.7, and also serves as a Fact Sheet as 

provided in 40 CFR § 124.8.
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2.0 Applicant Information

2.1 Applicant Name and Mailing Address

Shady Hills Power Company, LLC

800 Long Ridge Road

Stamford, Connecticut 06927

2.2 Facility Location

Shady Hills is proposing to modify the existing Shady Hills Generating Station located on 14240 

Merchant Energy Way within the City of Spring Hill, in Pasco County, Florida. The site location is 

illustrated in Figures 2-1 and 2-2 below.

Figure 2-1 Pasco County, FL

Figure 2-2 Shady Hills Project Boundary

Pasco County
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3.0 Proposed Project

Shady Hills has applied for a GHGs PSD air permit pursuant to the CAA from the EPA Region 4 for the 

proposed Project. Shady Hills is proposing to build two additional, simple cycle combustion turbines

(Model: General Electric 7FA.05) [Emissions unit (EU) 005 and 006]. The GE 7FA.05 output is 218 

MW (gross) when firing natural gas and 223 MW (gross) when firing ULSD fuel oil. The simple cycle 

combustion turbine (SCCT) will have low-nitrogen oxide combustion technology when firing natural 

gas and water injection for NOx control when firing ULSD fuel oil. The primary fuel will be natural gas 

with ULSD fuel oil with sulfur content is 0.015 percent as backup fuel. The heat input per turbine would 

be 2,135 million British thermal units per hour (MMBtu/hr), higher heating value (HHV). 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), an SF6 circuit breaker (EU 010), and 

new on-site natural gas pipeline.

The project will result in a net emission increase greater than PSD threshold limits for TSP, PM10, PM2.5,

NOx, and GHGs. On April 6, 2012, the FDEP issued their portion of the construction permit to the 

applicant (PSD-FL-402A/1010373-012-AC), which addressed all pollutants mentioned except for 

GHGs. The expiration date of the revised construction permit is July 31, 2015. The EPA is responsible 

for issuing the GHG portion of the PSD permit. The Project cannot be constructed until both the FDEP 

and the EPA PSD permits are issued and effective.

SHGS will result in a net increase of 69 TPY of TSP/PM10/PM2.5, 397 TPY of NOx, and 923,502 TPY of

GHG emissions on the basis of carbon dioxide equivalent (CO2e). Based on emissions estimates and the 

applicable permitting thresholds, SHGS will have significant emissions of GHGs on a mass and CO2e

basis and is subject to the PSD program for GHGs as the measured pollutant. Based on Shady Hills’s 

permit application, GHG emissions will experience a net increase of 923,502 TPY of CO2e. 

Shady Hills’s existing facility consists of three, dual-fuel, 170 MW (nominal) GE PG7241FA simple 

cycle combustion turbine (SCCT)-electrical generators, three 75 feet high exhaust stacks, and one 2.8 

million gallon ULSD fuel oil storage tank. The combustion turbine units can operate in simple-cycle 

mode and intermittent duty mode. The units are equipped with dry low-NOx combustors and water 

injection capability. The three units are regulated under Phase II of the Federal Acid Rain Program. The 

existing facility and the Project are located at 14240 Merchant Energy Way within the City of Spring 

Hill, in Pasco County, Florida. The Project will be located within the existing Shady Hills boundaries. 

The facility has been in operation since 2002 and operates during peak hours of electrical use.

EUs 001 through 004 were constructed under PSD-FL-280/1010373-001-AC and authorized to operate 

pursuant to FDEP final title V permit no. 1010373-003-AV. The three 170 MW SCCTs (EUs 001-003) 

are allowed to fire natural gas and No. 2 fuel oil or higher grade. EU 004 is the existing 2.8 Mgal ULSD

fuel oil storage tank.

The applicant proposed two different operating scenarios. The first (base) scenario is the installation and 

operation of two SCCTs for an average of 3,390 hours per year at full load per CT (but not more than 

5,000 hours/year for a single unit). The CTs will use natural gas as the primary fuel with ULSD fuel oil 

used as a backup fuel for up to the equivalent of 1,000 combined hours per year (hr/yr) at base load

conditions. 
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PSD-EPA-R4013

The second (alternate) scenario consists of the installation and operation of only one SCCT for a 

maximum of 3,390 hours per year of which up to 750 hr/yr would using ULSD fuel oil as backup. After 

reaching the first 500 hours of firing ULSD fuel oil, the remaining 250 hr/year will be under an 

operating hour trade-off mechanism consisting of 390 hour of natural gas only, or 78 hours of ULSD 

fuel oil only, or a combination following a 5:1 trade-off ratio. In this situation, the worst-case emissions 

scenario is where the CT operates using ULSD fuel oil for the maximum amount of 750 hours per year

and the CT would be able to run with natural gas for a maximum 1,640 hrs/yr.

Natural gas for SHGS will be transported to the facility via pipeline. No onsite storage will be provided 

for natural gas. New onsite pipeline and natural gas supply will be installed. ULSD oil will be delivered 

to the facility by truck and stored in a new ULSD fuel oil storage tank with a 2.8 Mgal capacity.

[THIS SPACE WAS INTENTIONALLY LEFT BLANK]
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PSD-EPA-R4013

4.0 Legal Authority and Regulatory Applicability

4.1 EPA Jurisdiction

In 2010, the EPA established a federal implementation plan (FIP) to apply in each state that had not 

submitted by their established deadline a corrective state implementation plan (SIP) revision to apply 

their CAA PSD program to sources of GHGs. See 75 FR 82246 (Dec. 30, 2010). The State of Florida is 

subject to the FIP; therefore, the EPA is issuing this GHG PSD permit. FDEP is responsible for issuing a 

separate construction and title V operating permit for the Project for regulated pollutants other than 

GHGs.

4.2 Prevention of Significant Deterioration (PSD)

The PSD program, as set forth at 40 CFR § 52.21, is applicable to major sources such as this proposed 

project. The objective of the PSD program is to prevent significant adverse environmental impact from 

air emissions by a proposed new or modified source. The PSD program limits degradation of air quality 

to that which is not considered “significant.” The PSD program requires an assessment of air quality 

impacts of the proposed project, and also requires the utilization of BACT as determined on a case-bycase basis taking into account energy, environmental and economic impacts, and other costs.

Under the PSD regulations, a stationary source is “major” if, among other things, it emits or has the 

potential to emit (PTE) 100 TPY or more of a “regulated New Source Review (NSR) pollutant” as 

defined in 40 CFR § 52.21(b)(50) and is “subject to regulation” as defined in 40 CFR § 52.21(b)(49) and 

the stationary source is one of a named list of source categories. In addition to the preceding criteria, any 

stationary source is also considered a major stationary source if it emits or has the potential to emit 250 

TPY or more of a regulated NSR pollutant. See 40 CFR § 52.21(b)(l). “Potential to emit” is defined as 

the maximum capacity of a source to emit a pollutant under its physical and operational design. “Any 

physical or operational limitation on the capacity of the source to emit a pollutant, including air 

pollution control equipment and restrictions on hours of operation or on the type or amount of material 

combusted, stored or processed, shall be treated as part of its design if the limitation or the effect it 

would have on emissions is enforceable.” See 40 CFR § 52.21(b)(4).

Beginning on January 2, 2011, GHGs became subject to regulation under the PSD major source 

permitting program as a regulated NSR pollutant when emitted in amounts greater than certain 

applicable thresholds. GHGs are a single air pollutant defined in 40 CFR 52.21(b)(49)(i) as the 

aggregate group of the following six gases:

 Carbon dioxide (CO2);

 Nitrous oxide (N2O);

 Methane (CH4);

 Hydrofluorocarbons (HFCs);

 Perfluorocarbons (PFCs); and

 Sulfur hexafluoride (SF6).
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PSD-EPA-R4013

Due to the nature of GHGs and their incorporation into the definition of “subject to regulation”, the 

determination of whether a source is emitting GHGs in an amount that triggers PSD applicability 

involves a calculation of the source’s CO2e emissions as well as its GHG mass emissions. Consequently, 

when determining the applicability of PSD to GHGs, there is a two-part applicability process that 

evaluates both:

 The sum of the CO2e emissions in TPY of the six GHGs, in order to determine whether 

the source’s emissions are a regulated NSR pollutant; and, if so;

 The sum of the mass emissions in TPY of the six GHGs, in order to determine if there is 

a major source or major modification of such emissions.

For PSD permits issued on or after July 1, 2011, PSD applies to new sources as well as existing sources 

not already subject to title V that emit, or have the potential to emit, at least 100,000 TPY CO2e and 

greater than zero TPY on a mass basis. In addition, sources that emit or have the potential to emit at least 

100,000 TPY CO2e and that undertake a modification that increases net emissions of GHGs by at least 

75,000 TPY CO2e and equal to or greater than 100/250 TPY on a mass basis will also be subject to PSD 

requirements.2

Table 5-2 lists the PTE for each regulated NSR pollutant from the Project, as well as the significant 

emission rate for each regulated NSR pollutant. The permit application and Section 5.0 of this document 

contain information on the emissions factors used to determine the PTE for the Project. 

SHGS is an existing PSD source and the net increase in GHG emissions associated with the 

modification exceeds the threshold of 75,000 TPY. Section 6.0 of this document contains a discussion of 

the BACT analysis. 

4.3 Title V

Upon issuance of this PSD permit, the State of Florida will incorporate these permit conditions into the 

existing title V permit for the facility.

4.4 New Source Performance Standards (NSPS)

On September 20, 2013, EPA signed a proposed NSPS that could influence the ultimate emission 

requirements for this source. The definition of BACT in PSD rules at 40 CFR 52.21(b)(12) states that 

“in no event shall application of best available control technology result in emissions of any pollutant 

which would exceed the emissions allowed by any applicable standard under 40 CFR parts 60 and 61.” 

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

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

final action and the proposed standard may change. However, the NSPS is an independent requirement 

that will apply to any source subject to the NSPS that commences construction after the date the NSPS is 

proposed (unless that source is covered by a transitional source exemption adopted in the NSPS). Thus, 

this facility may ultimately be subject to, and need to comply with, the NSPS after it is finalized, even if 

the emissions limits in the final permit are higher than the NSPS. See EPA, “PSD and Title V Permitting 

Guidance for Greenhouse Gases” (March 2011) at page 25.

 

2

Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule, 75 FR 31514 (3 June 2010).
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PSD-EPA-R4013

5.0 Project Emissions

The maximum annual potential emissions for the Project include GHG emissions from the SCCT, 

natural gas heater, emergency generator, and ULSD fuel oil storage tank. For the potential to emit (PTE) 

calculations, two scenarios were proposed. The worst-case emissions scenario was used in the annual 

potential emissions. Table 5-1 presents the maximum annual potential SHGS emissions from the 

operation of two SCCTs, Model GE7FA.05. This table addresses the relevant regulated NSR pollutants, 

as required under PSD. Table 5-2 summarizes the maximum annual emissions changes.

Table 5-1SHGS Potential to Emit Estimates, using GE 7FA.053

 

3

Information from Table 2-7 Summary of Maximum Potential Annual Emissions for the Shady Hills Generating Station 

Project as submitted in the application to FDEP dated July 9, 2010.

4 Represents the worst-case (baseload) scenario. The alternate scenario is the construction of one SCCT.

EU ID 

No.

Emission 

Unit 

Description

Potential to Emit Estimates (TPY)

SO2 TSP PM10 PM2.5 NOx CO VOC

Sulfuric 

Acid 

Mist

Lead GHGs 

(CO2e)

005 & 

006

Two (2) 

SCCTs 

GE7FA.054

29.6 69.0 69.0 69.0 386.3 88.4 13.6 4.5 0.015 918,618

007

2.5 MW 

Emergency 

Generator

0.01 0.35 0.35 0.35 8.91 6.17 2.38 NA NA 859

008

10 MMBtu/hr 

Natural Gas 

Heater

0.07 0.12 0.12 0.12 1.61 1.35 0.09 NA NA 3,965

009

2.8 Mgal 

ULSD Fuel 

Oil Storage 

Tank

NA NA NA NA NA NA 2.02 NA NA NA

010

Three SF6

Circuit 

Breakers

NA NA NA NA NA NA NA NA NA 12

Fugitives

On-site 

Pipeline and 

Natural Gas 

Supply

NA NA NA NA NA NA NA NA NA 47

Total Project 29.7 69.5 69.5 69.5 396.8 95.9 18.1 4.5 0.015 923,502
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PSD-EPA-R4013

Table 5-2 Summary of Maximum Annual Emissions Changes

Pollutant PTE 

(TPY)

Significant Emission 

Rate (TPY) PSD Review Required

SO2 29.71 40 No

TSP 69 25 Yes

PM10 69 15 Yes

PM2.5 69 10 Yes

NOx 386.3 40 Yes

CO 96 100 No

VOC (as methane) 18 40 No

Sulfuric Acid 

Mist 5 7 No

Lead 0.015 0.6 No

GHGs (CO2e) 923,502 75,000 (subject to 

regulation threshold) Yes

As seen in the emissions summary tables, the emissions limits are based upon net changes to emissions 

associated with future equipment.

5.1 Emission Unit Analysis 

Emissions calculations for equipment used during operation of SHGS were made based on the 

assumptions described below.

EU 005 and 006 – Two 223 MW GE7FA.05 SCCTs 

Performance, estimated maximum hourly emissions, and exhaust information representative of each 

SCCT operating at base load conditions (100% load) in simple cycle mode are presented in Table 5-1 

when firing natural gas and ULSD oil firing. The data are presented for a maximum heat input rate of 

2,265 MMBtu/hr when firing ULSD fuel oil. Maximum potential annual emissions for the SCCTs for 

regulated air pollutants are based on an ambient temperature of 59°F, 60% relative humidity, and 14.7 

pounds per square inch (psi). The turbine inlet temperature (59°F) is conservative, since the annual 

average temperature is slightly higher than 59°F. The volumetric flow rate is 2,780,256 actual cubic feet 

per minute (acfm).

The applicant proposed two potential scenarios, the base scenario and the alternate scenario. In the base 

scenario two CTs are built. To produce the maximum annual emissions, it is assumed that each CT 

would operate for 3,390 hours per year. Of the 3,390 operating hours, an average of 2,890 hr/CT/yr are 

assumed to be natural gas firing only. One single turbine can operate for not more than 5,000 hours per 

year. For the remaining operating hours, the CTs are assumed to run on ULSD fuel oil for a maximum 

of 1,000 hr/CT/yr combined. The alternate scenario proposes the construction of only one CT. It is 

assumed that it will operate for a maximum 3,390 hours per year. Of the 3,390 operating hours, an 

average of 1,640 hr/CT/yr are assumed to be natural gas firing only. The other 750 operating hours, the 

applicant proposed to run a maximum of 500 hours on ULSD fuel oil and apply a trade-off mechanism 

for the rest of the 250 operating hours. The trade-off consists of natural gas versus ULSD fuel oil at 5:1 

ratio. 
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PSD-EPA-R4013

EU 007- 2,500 kW Emergency Generator

SHGS will be equipped with one 2,500 kilowatt (kW) emergency generator firing ULSD fuel oil. This 

emergency generator will be used when electric power is not available in situations such as plant power 

outages and black start conditions. Normally, these emergency generators would be operated 1 to 2 

hours per month for maintenance and reliability testing. PTE emissions were calculated based on a

maximum of 500 hours of operation. The applicant will meet the requirements of 40 CFR 60.4211(f) 

limiting non-emergency use of the emergency generator to 100 hr/yr.

EU 008- 10 MMBtu/hr Natural Gas Heater

SHGS may include one natural gas-fired fuel heater. This heater will be indirectly-fired with natural gas 

only and utilize a heat transfer fluid for heating the natural gas. This heater will have a maximum heat 

input rate of 10 MMBtu/hr (HHV) or less and will be used as necessary to heat natural gas above the 

dew point.

EU 009- 2.8 Mgal ULSD Fuel Oil Storage Tank

ULSD fuel oil will be trucked to the facility and stored in a new aboveground storage tank at the facility. 

This tank has a rated storage capacity of approximately 2.8 million gallons (67,000 barrels). This is a 

source of negligible amounts of GHG emissions.

EU 010 – Circuit Breakers

Three new circuit breakers containing sulfur hexafluoride (SF6) is proposed. The breaker provides for 

electrical insulation and interruption of electrical current. The proposed circuit breakers are designed as 

totally enclosed pressure system with minimal potential for SF6 emissions.

Fugitives – On-Site Pipeline and Natural Gas Supply

New pipelines will be installed to supply natural gas to the new SCCTs and the natural gas heater.

5.2 Compliance Methodology (Monitoring, Recordkeeping, and Reporting)

The applicant proposed to monitor compliance with the CO2e BACT limits for the SCCTs (EU 005 & 

006) at all times through the installation of a continuous monitoring system. The monitored data

(including gross energy output rate, CO2 mass emission rate, heat input rate) will be used to determine 

CO2e emissions based on 40 CFR Part 75 for CO2 emissions. The applicant will calculate, record and 

maintain record files according to requirements in the permit.

The applicant will limit the hours of operation of the emergency generator (EU 007) to 100 hours per 

12-month rolling total for maintenance and testing purposes (in accordance to 40 CFR 63 Subpart 

ZZZZ). The natural gas heater (EU 008) will be limited to a maximum of 3,965 TPY of CO2e emissions. 

Work Practice Standards will be required to minimize GHGs from the circuit breakers (EU 010) and 

fugitive emissions from the natural gas pipeline.
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6.0 Best Available Control Technology (BACT) and Recordkeeping 

Requirements

A major modification of a major stationary source subject to PSD requirements is required to apply 

BACT for each pollutant subject to regulation under the CAA that it would have the potential to emit in 

significant amounts. See 40 CFR § 52.21(j). Based on the emissions inventory for SHGS, summarized in 

Table 5-2, Shady Hills has the potential to emit NOx, TSP/PM10/PM2.5, and GHGs in quantities that 

equal or exceed the significant emission rate. Based on their authority, FDEP has permitted the NOx, 

TSP, PM10, and PM2.5 emissions for the Project. However, the EPA is responsible for permitting the 

GHG emissions. Therefore, BACT must be determined for each emission unit which emits GHGs as 

part of the EPA-issued permit.

The two simple cycle combustion turbines are included in the source’s potential to emit, as required by 

40 CFR 52.21(b)(4), and are subject to operating limits as well as monitoring, recordkeeping and 

reporting requirements to ensure they will not exceed the potential emissions assumed in the application 

and impact review. In addition, the application includes an emergency generator, a natural gas heater, a

ULSD fuel oil storage plant, an electric breaker and new on-site natural gas pipeline, which are 

necessary support equipment for the two SCCTs. These are also subject to operating limits, monitoring, 

recordkeeping and reporting requirements.

BACT is defined in the applicable permitting regulations at 40 CFR § 52.21(b)(12), in part, as:

an emissions limitation (including a visible emission standard) based on the maximum 

degree of reduction for each pollutant subject to regulation under the Act which would be 

emitted from any proposed major stationary source or major modification which the 

Administrator, on a case-by-case basis, taking into account energy, environmental, and 

economic impacts and other costs, determines is achievable for such source or 

modification through application of production processes or available methods, systems, 

and techniques, including fuel cleaning or treatment or innovative fuel combustion 

techniques for control of such pollutant. 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. If the Administrator 

determines that technological or economic limitations on the application of measurement 

technology to a particular emissions unit would make the imposition of an emissions 

standard infeasible, a design, equipment, work practice, operational standard, or 

combination thereof, may be prescribed instead to satisfy the requirement for the 

application of best available control technology. 

The CAA contains a similar BACT definition, although the 1990 CAA amendments added “clean fuels” 

after “fuel cleaning or treatment” in the above definition. See CAA § 169(3).

On December 1, 1987, the EPA issued a memorandum describing the top-down approach for 

determining BACT. See, e.g., In re Prairie State Generating Co., 13 E.A.D. 1 (EAB 2006). In brief, the 

top-down approach provides that all available control technologies be ranked in descending order of 

control effectiveness. Each alternative is then evaluated, starting with the most stringent, until BACT is 

determined. The top-down approach consists of the following steps:
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PSD-EPA-R4013

Step 1: Identify all available control technologies.

Step 2: Evaluate technical feasibility of options from Step 1 and eliminate options that are 

technically infeasible based on physical, chemical and engineering principles. 

Step 3: Rank the remaining control technologies from Step 2 by control effectiveness, in 

terms of emission reduction potential.

Step 4: Evaluate the most effective controls from Step 3, considering economic, 

environmental and energy impacts of each control option. If the top option is not selected, 

evaluate the next most effective control option.

Step 5: Select BACT (the most effective option from Step 4 not rejected).

6.1 GHG BACT Analysis for two 223 MW GE7FA.05 SCCTs

Typically, a base load power generating unit consists of combined cycle combustion turbines (CCCTs)

and other ancillary equipment. CCCTs operate at a higher efficiency. However, Shady Hills is a peaking 

plant. Electric utilities primarily use simple-cycle combustion turbines as peaking or backup units. Their 

relatively low capital costs and quick start-up capabilities make them ideal for partial operation to 

generate power at periods of high demand or to provide ancillary services.5Peaking power is needed 

during periods of high energy demands, for example in the afternoons. Therefore, since the CCCTs have 

a longer startup and shutdown period, Shady Hills requires a combustion turbine that is capable of a 

short startup period. Simple cycle CTs are suitable for this purpose.

The applicant discussed the challenges of installing CCCTs for this particular project. As described 

above, this Project has the objective of expanding the Shady Hills operations by increasing the amount 

of peaking power generated. Consistent with this objective, the applicant has agreed to limit its hours of 

operation to no more than 3,390 hours per CT annually. The EPA agrees with this assessment,

consequently, the CCCTs were considered a redefinition of the source and were not considered in the 

BACT analysis.

Step 1: Identify all available control technologies

The applicant identified the following available control technologies in their permit application dated 

September 21, 2012, for the proposed two 223 MW GE7FA.05 simple cycle combustions turbines: 

1. Clean Fuels

2. Energy Efficiency

3. Carbon Capture and Storage (CCS)

In addition, the EPA requested that Shady Hills submit justification for the use of ULSD fuel oil as a 

backup, along with the appropriate BACT analysis, since a complete BACT analysis should also include 

the evaluation of clean fuels and combustion of natural gas generally results in lower GHG emissions 

than does the combustion of ULSD fuel oil.

 

5 EPA OAQPS Economic Impact Analysis of the Proposed Stationary Combustion Turbines NESHAP , Final Report, 

November 2002, http://www.epa.gov/ttnecas1/regdata/IPs/Stationary%20Combustion%20Turbines_IP.pdf
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PSD-EPA-R4013

Clean Fuels: Clean fuels fall under the general category of lower polluting processes/practices. Natural 

gas is an inherently cleaner burning fuel that is ubiquitous in the US and can be produced domestically6.

The combustion of natural gas emits about 30% less CO2 than oil. 

The applicant considered two scenarios for clean fuels. The first scenario is using 100% dedicated 

natural gas operation. The second scenario includes a range of 750 hr/yr to 1,000 hr/yr ULSD oil fuel 

burning along with natural gas as the primary fuel. ULSD with 0.015% sulfur is proposed as the backup 

fuel.

Energy Efficiency: Energy efficiency falls under the general category of lower polluting 

processes/practices. Applying technologies, measures and options that are energy efficient translates not 

only in the reduction of emissions of the particular regulated NSR air pollutant undergoing BACT 

review for GHGs, but it also may achieve collateral reductions of emissions of other pollutants. There 

are different categories of energy efficient improvements:

 Technologies or processes that maximize the efficiency of the individual emissions unit, and

 Options that could reduce emissions by improving the utilization of thermal energy and 

electricity that is generated and used onsite. 

When the efficiency of the power generation process is increased, less fuel is burned to produce the 

same amount of electricity. This provides the benefits of lower fuel costs and reduced air pollutant 

emissions (including GHGs). 

Carbon Capture and Storage (CCS): Carbon capture and storage (CCS) falls under the category of addon controls, which are air pollution control technologies that remove pollutants from a facility’s 

emissions stream. CCS is an add-on pollution control technology that is available for large CO2 emitting 

facilities including fossil fuel-fired power plants and industrial facilities with high purity CO2 streams. 

As a result, CCS should be considered in Step 1 of the BACT analysis. CCS is composed of three main 

components: CO2 capture and/or compression, transport, and storage. 

Deep saline formations, which are layers of porous rock, saturated with brine present a potential for 

geologic storage of CO2. However, there is not as much experience with saline formations as there is 

acquired through resource recovery from oil and gas reservoirs and coal seams. There is ongoing 

research focused on storage in organic rich shale, which is a thin horizontal layer of sedimentary rock 

with low vertical permeability and in basalt formations, which are geologic formations of solidified lava. 

Other possible options include liquid storage in deep ocean areas.

Step 2: Eliminate technically infeasible control options

To establish that an option is technically feasible, the permitting record should show either that an 

available control option has been demonstrated in practice or is available and applicable, with the term 

“applicable” generally meaning a technology can reasonably be installed and operated on the source 

type under consideration.

Clean Fuels: The use of natural gas as the primary fuel to run the SCCTs is technically feasible and is 

being proposed for the SHGS simple cycle CTs. Two scenarios were considered: exclusively using 

 

6

http://www.epa.gov/cleandiesel/technologies/fuels.htm
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PSD-EPA-R4013

natural gas to run the CTs and using natural gas as the primary gas along with ULSD oil as the backup 

fuel.

Energy Efficiency: Efficient power generation is technically feasible and is being proposed for the 

SHGS simple cycle CTs. As a reference, Shady Hills considered the GHG BACT analysis for Puget 

Sound Energy Fredonia Generating Station Expansion Project located in Mount Vernon, Washington, 

dated October 2011. On this BACT analysis, Puget Sound analyzed six different turbines, similar in 

capacity and from different manufacturers (i.e., General Electric (GE) LMS100, GE LM6000, GE 

7FA.05, Siemens, 5000F4, and P&W FT8-3). Shady Hills decided to focus their BACT analysis on 

those SCCTs that were the equal or higher in efficiency than the GE 7FA.05 model.(i.e., GE 7FA.05, 

LMS 100, LM 6000). The GE 7FA.05 is the latest version of the GE 7FA CTs. It is more efficient than 

previous models, 7FA.04 and 7FA.03.

Additionally, on the response to the EPA’s request for additional information dated November 30, 2012, 

the applicant confirmed that at the moment no new more efficient turbine models of similar size to the 

GE 7FA.05 has become available since October 2011.

Carbon Capture and Storage (CCS): The EPA recognizes the logistical hurdles that the installation and 

operation of a CCS system presents which set this pollution technology apart from other add on controls 

that are typically used to reduce emissions of other regulated pollutants. It should also be noted that,

while CCS may be available, all current CCS projects for power plants are either in the demonstration 

stage or newly permitted and there have been no CCS demonstrations on simple cycle combustion 

turbines. Logistical hurdles identified by the applicant for CCS include obtaining contracts for offsite 

land acquisition (including the availability of land), the need for funding (including, for example, 

government subsidies), timing of available transportation infrastructure, developing a site for secure 

long term storage and environmental permitting for underground GHG sequestration. Each of the three 

aspects of CCS is discussed below:

Carbon Capture: The EPA Region 4 considered the EPA Region 9’s Pio Pico Energy Center 

(PSD Permit Number SD 11-01) Fact Sheet and Ambient Air Quality Impact Report for the main 

approaches to carbon capture.7 As with the Pio Pico project, post-combustion capture using an 

amine solvent would be the CO2 capture approach that is most applicable to the simple cycle gas 

turbines in the Shady Hills project. Furthermore, as determined in the Pio Pico BACT analysis, 

the EPA believes that post-combustion capture is technically infeasible due to the variable 

operation of simple cycle combustion turbines and the flue gas cooling and heat integration 

issues. Please refer to the cited document for additional information on the feasibility of postcombustion capture approach for simple cycle gas turbines.

Carbon Transport: The Sunniland Trend’s most northern tip is in Lee County; however, the 

Project is located in Pasco County. The distance between the Project’s site and Lee County is 

approximately 160 miles by road. Florida’s lack of infrastructure to transport CO2 via pipeline

adds to the hurdle of transporting the captured CO2. The closest CO2 enhanced oil recovery site 

with a connection via pipeline is located in Mississippi8.

 

7

Pio Pico Energy Center (PSD Permit Number SD 11-01) Fact Sheet and Ambient Air Quality Support Report, June 2011, 

pp 15-22.

8 Carbon Dioxide Enhanced Oil Recovery: Untapped Domestic Energy Supply and Long Term Carbon Storage Solution, 

United States Department of Energy, March 2010.
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PSD-EPA-R4013

Carbon Storage: The Sunniland Trend in South Florida is an arcuate trend about 235 kilometers 

long by 30 kilometers wide that has supported oil production from the Sunniland Formation for 

over 60 years. The individual oil fields within the Trend have an average porosities range of 15-

18%, and the potential to serve as CO2 sequestration reservoirs due to their high porosity and 

proven ability to trap hydrocarbon for millennia. The non-oil-bearing porous intervals of the 

Sunniland Formation along the Trend have relatively high porosities as well, with an average 

porosity range of 10-20%. All porous intervals in the Sunniland Formation within the extent of 

the Trend, including the oil-bearing intervals, have the potential to store approximately 1.2 

billion tons of CO2, which could potentially support CO2 sequestration for multiple large-scale 

power plants in the southeastern United States for their entire 40 year lifespan. 

The Sunniland Formation is an example of the large CO2 storage capacities that are potentially 

available in depleted oil and gas basins if all porous units, including those which are non-oil 

bearing, are considered for storage.9 As part of the conclusion for this study, the researchers 

recommended further geophysical evaluation to have a better determination of the suitability of 

the upper seal prior to the implementation of any CO2 injections into the Sunniland Formation.

The applicant believes that CCS is technically infeasible for the Shady Hills project; however, 

the applicant included a CCS economic analysis for consideration in Step 4 of the BACT 

analysis. Based on the technical barriers to capture CO2, as identified and discussed in the Pio 

Pico permit documents, as well as the potential concerns raised by the applicant regarding CO2

transportation in Florida and the capabilities of the nearest geologic storage (Sunniland Trend),

the EPA has determined that CCS is technically infeasible as a control technology for this simple 

cycle project. Consequently, the EPA did not consider the economic analysis provided by the 

applicant in our BACT determination. 

Step 3: Rank remaining control technologies

Based on the discussion in Steps 1 and 2, clean fuels and energy efficiency were considered technically 

feasible as control options. Further analysis of each of them is included in Step 4.

Clean Fuels: The combustion of natural gas emits about 30% less CO2 than oil.

Energy Efficiency: The GE 7FA.05, LM6000, and LMS100 CTs were compared to each other. The 

applicant only considered those turbines that were at the same level of efficiency or higher than their 

proposed model GE 7FA.05. The top control is a combination of the cleanest fuel and the most energy 

efficient combustion turbine. In Step 4 the economic, energy, and environmental impacts of these 

technologies are analyzed.

Step 4: Economic, Energy, and Environmental Impacts

Clean Fuels: The applicant considered two scenarios: (1) exclusively using 100% non-interruptible 

natural gas to run the CTs and (2) using natural gas as the primary gas along with ULSD fuel oil as the 

backup fuel. Per the EPA’s request, the applicant submitted in the Response to the Notice of 

Incompleteness letter dated November 30, 2012, a BACT analysis including the consideration of 100% 

non-interruptible natural gas.

 

9 Roberts-Ashby, T.; Stewart, M.; Potential for carbon sequestration in the Lower Creataceous Sunniland Formation within 

the Sunniland Trend of the Sour Florida Basin, U.S., International Journal of Greenhouse Gas Control, 2012, pp 113-225.
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PSD-EPA-R4013

100% Non-interruptible Natural Gas

The procurement of firm natural gas transportation for a peaking plant adds to the fixed 

operating costs. The nature of the SHGS project, where it is limited to operate no more than 

3,390 hours per CT annually, makes the procurement of 100% non-interruptible natural gas for 

8,760 hours per year incompatible with the Project. It increases the economic impacts of the 

Project. Current tariff rates for firm transportation are more than 2.5 times higher than 

interruptible transportation. The updated cost analysis including the 100% non-interruptible 

natural gas option shows this is not a feasible option due to the high cost when applied to the 

base scenario (construction of two SCCTs). The calculations show that the non-interruptible 

natural gas option is more expensive ($286.2 per ton of CO2e removed) than the option with 

interruptible transportation of natural gas with ULSD fuel oil as backup fuel.

Since the EPA has determined that the use of 100% non-interruptible natural gas is not economically 

feasible, the use of natural gas as the primary fuel with ULSD fuel oil as back up is determined feasible 

for this project.

Energy Efficiency: The applicant considered three different turbines (i.e., LMS100, LM6000, and 

7FA.05) before choosing the 7FA.05 as their final choice. As described in Table 6-1 below, LMS 100 

and LM 6000 are more efficient than the GE 7FA.05. Based on the projected generation of 425 MW or 

more, the applicant would need a total of four LMS100 CTs, ten LM6000 CTs, or two 7FA.05 to 

produce the equivalent energy output. 

When compared among each other, for the same output (425 MW), the LMS100 would emit about 

108,130 TPY of CO2e emissions less than the 7FA.05 and the LM6000, 72,576 TPY less than 7FA.05. 

Although LMS100 and LM6000 remain the top CTs when considering the CO2e emissions, the 

environmental, energy, and economic impacts still need to be assessed.

Based on Attachment H of the application, consisting of the GHG BACT analysis for Puget Sound 

Energy Fredonia Generating Station Expansion Project, the heat rate at full load for each of the turbines 

are listed in the following table. The heat rate indicates the amount of energy required to produce a 

kilowatt-hour of electricity. Therefore, a lower heat rate number translates to a higher thermal efficiency 

of the turbine.

Table 6-1 Efficiency from Available Turbine Options10

7FA.05 LM6000 LMS100

Manufacturer GE GE GE

Technology Aero Aero Frame

Heat rate @ Full Load (Btu/kWh, HHV)

Natural Gas 8,848 9,226 9,910 

Heat rate @ Full Load (Btu/kWh, HHV)

ULSD oil 8,625 9,083 10,388 

CO2e emissions (TPY) 904,094 831,519 795,965

Rank (1=lowest emitting) 1 2 3

 

10 Refer to Table 2 and 2a of the PSD GHG application dated September 2012 for additional details.
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PSD-EPA-R4013

The LMS100 is a small aeroderivative simple cycle CT with the capability to produce 100 MW within 

10 minutes.11 The applicant would need to install a total of four LMS100s to produce around 400MW, 

which is close to the 425 MW they are proposing to produce. The LMS100 CT is suitable for use in a 

peaking power generation plant. It has a high base load (thermal) efficiency of 44%.

The LM6000 is a smaller aeroderivative simple cycle CT with the same quick start capability of the 

LMS100.12 Since the CT is able to produce around 41 MW, the applicant would need to install around 

10 LM6000 to produce approximately 416 MW. This SCCT is suitable for peaking power generation. It 

has a high base load (thermal) efficiency of 42%.

The GE 7FA.05 has a 38.5% thermal efficiency. The LMS 100 gas turbines have a maximum efficiency 

of 44% under ISO conditions.13 The GE 7FA.05 ranked as the least efficient combustion turbine when 

compared to the LM6000 and LMS100 simple cycle combustion turbines. However, when the 

economic, energy, and environmental impacts are considered all together, the GE7FA.05 remained the 

most efficient control technology.

The applicant submitted an updated cost effectiveness analysis in the response to the notice of 

incompleteness determination dated November 30, 2012. Both scenarios, the base and the alternate, 

were considered. The EPA considered the capital and operational costs of the three SCCTs (7FA.05, 

LMS100 and LM6000). If analyzed according to the cost per ton of CO2e removed, the cost for the ten 

LM6000 units would be $286.8 per ton of CO2e removed more than the 7FA.05. For the four LMS100 

the cost would be $61.9 per short ton of CO2e more than the 7FA.05.

The water needs for two 7FA.05 SCCTs is expected to be around 165,000 gallons per day (GPD) on an 

annual average daily basis (firing natural gas and ULSD fuel oil as backup), the four LMS100s are 

expected to utilize 330,000 GPD on an annual average daily basis for NOx emission control. The great 

amount of water consumption by the four LMS100 is a considerable environmental impact. 

The LM6000 SCCT does not use water injection to control NOx emissions; however, the amount of NOx

emissions (15 ppm) is higher than permitted. This particular SCCT generates additional NOx, CO, and 

ammonia slip emissions. If either LMS100 or LM6000 was chosen as the SCCT for this facility, the 

applicant would need to install additional NOx and CO control technologies. Although both the LMS100 

and the LM6000 turbines are slightly more efficient than the GE 7FA.05, the environmental impacts 

they would have if constructed makes them infeasible.

Considering the higher costs for removing GHG emissions, the increased water usage, and the higher

NOx emissions, the EPA agrees that the most effective combination of control technologies is the use of 

model GE 7FA.05 combustion turbines operated using interruptible natural gas service and ULSD fuel 

oil as backup only.

Step 5: Selection of BACT

Shady Hills proposed gross output-based GHG BACT limits for “normal” operation of 1,377 lb 

CO2e/MW-hr on a 12-month rolling average when using natural gas and a gross output-based GHG 

 

11 http://www.ge-energy.com/products_and_services/products/gas_turbines_aeroderivative/lms100.jsp, accessed May 2013.

12 http://www.ge-energy.com/products_and_services/products/gas_turbines_aeroderivative/lm6000.jsp, accessed May 2013.

13 Pio Pico Energy Center Fact Sheet and Ambient Air Quality Impact Report. June 2012.
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PSD-EPA-R4013

BACT limit of 1,928 lb CO2e/MW-hr on a 12-month rolling average when using ULSD fuel oil. The 

BACT limits are based on per turbine operation, ISO conditions14, the range in operating loads, 2,890 

hr/yr of natural gas operation, 1,000 hr/yr of ULSD oil operation, a 3 percent margin for the difference 

between guaranteed heat rates and actual heat rates, and a 5 percent margin for degradation over time.

The applicant also proposed GHG BACT limits for natural gas and ULSD oil during for startup and 

shutdown events. The proposed limits are based on the assumption that each startup and shutdown time 

is 15 minutes. Each year, an estimated 250-300 startups/shutdowns per CT are expected to occur.

Table 6-2 Proposed BACT for the SCCTs

Type of Fuel Normal Operation

(lb CO2e/MW-hr)aper turbine

Startup and Shutdown

(tons CO2e /event)b

Natural gas 1,377 21

ULSD oil 1,928 28

a. Gross, 12-month rolling average; ISO conditions

b. Estimated startup and shutdown event would be 15 minutes long; 250-300 startup/shutdown events annually

Based on the BACT analysis, the proposed GHG BACT limits during normal operation conditions of 

1,377 lb CO2e/MW-hr (natural gas) and 1,928 lb CO2e/MW-hr (ULSD fuel oil) on a 12-month rolling 

average is appropriate as BACT.

Based on the BACT analysis, the proposed GHG BACT limits during startup and conditions of 21 tons

CO2e per event (natural gas) and 28 tons CO2e per event (ULSD fuel oil) per event (12-month rolling 

average) is appropriate as BACT.

6.2 GHG BACT Analysis for Smaller Combustion Equipment: Emergency Generator (EU 007) 

and Natural Gas Fuel Heater (EU 008)

CCS is not practical for control of CO2 emissions from the emergency generators and natural gas fuel 

heater due to the small amount of CO2 emissions potential from this equipment compared to the simple 

cycle system. Moreover, these units are not operated continuously or at their rated capacities making the 

addition of control equipment problematic. Therefore, CCS was not included as an available control 

technology in the following BACT analysis.

Step 1 & Step 2: Identify all available control technologies and eliminate technically infeasible 

control options

The applicant identified the following available control technologies in their permit application dated 

September 2012 for the proposed emergency generator and natural gas fuel heater.

Clean Fuels: The applicant considered the possibility of operating a biodiesel- or natural gas-fired 

emergency generator. Biodiesel was eliminated as non-feasible due to its inherent properties. The 

biodiesel might affect the integrity of certain components such as rubber hoses and seals and may cause 

dissolvation and clogging due to sedimentation of dissolved components. Separation, congealing and 

degradation of the biodiesel are also a concern. The application also alluded to the limited amount of 

biodiesel emissions data for emergency generators as a disadvantage.

 

14 ISO conditions = 59 deg. F, 60% humidity, 14.7 psia
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PSD-EPA-R4013

On the other hand, natural gas-fired engines startup time is between 30 seconds to two minutes

compared to 10 seconds startup for diesel fired engines. Cummins Power Generations15 offer different 

fuel-fired emergency generators. The spark-ignited gas generators are available within a range of 5 kW 

to 150 kW. The lean-burn gas generators range from 315 kW to 2 MW in size. The diesel generators are 

available in sizes ranging from 10 kW to 2.5 MW, which includes the size of the proposed emergency 

generator. Caterpillar gas fueled standby generators range from 85 kW to 1040 kW16 in size.

The applicant presented information demonstrating that a natural gas-fired generator with the rating 

needed for this project is not available. On the other hand, diesel generators with the required rating are 

readily available. The longer startup time of a natural gas-fired engines compared to that of a diesel-fired 

engines is also a decision factor.

Due to the disadvantages of biodiesel as a fuel and lack of availability of natural gas-fired generators 

with the proposed rating, these fuels are deemed technically infeasible for the proposed emergency 

generator. The EPA recognizes that, with the exception of the emergency generator, the other 

combustion equipment (Fuel Heater, EU 008) in this BACT analysis utilize natural gas as the only fuel 

source, which is a cleaner fuel with respect to GHG emissions and constitutes a lower polluting method 

of operation. For the fuel heater, the GHG emissions rate for natural gas firing is 116.9 lb CO2e/MMBtu 

compared to 163.0 lb CO2/MMBtu for ULSD fuel oil firing based on Subpart C of 40 CFR Part 98, 

Mandatory Greenhouse Gas Reporting Rule. The emission factors include N2O and CH4 at the 

equivalent rates. Therefore, firing natural gas will generate less GHG emissions than firing oil.

Energy Efficiency: The natural gas heater may be used to warm up the natural gas flowing through the 

pipeline before feeding into the CTs. The heater supplies heat based on the natural gas conditions. 

Therefore, the amount of fuel used in the heater is regulated to that necessary for the natural gas 

delivered to the CT. The indirect-fired natural gas fuel heaters operate at a high thermal efficiency, 

usually greater than 75%. 

The emergency generator is designed to meet the applicable NSPS and National Emission Standards for 

Hazardous Air Pollutants for non-road engines (subparts IIII and ZZZZ, respectively); thus, this unit will 

maximize efficiency while meeting the required emissions standards. In conjunction with maximizing 

efficiency, the applicant also proposed proper maintenance and operating procedures.

The applicant has proposed to limit the operation of the emergency generator to 100 hours per 

year, excluding emergencies, for routine testing and maintenance purposes in order to qualify as 

an emergency generator under the regulations cited above.

The natural gas fuel heater operation is limited by the maximum amount of hours the SCCTs are 

allowed to operate, 3,390 hours per year per CT, for a total of 6,780 hr/yr.

Energy efficiency, limitation of hours of operation and clean fuels (for non-emergency equipment) 

through the regulation of the amount of fuel used is considered to be the only technically feasible CO2

control option for the emergency generator and natural gas heater.

 

15 http://cumminspower.com/en/products/generators/

16 Cat Generator Set Specs, http://www.cat.com/cda/layout?m=206981&x=7&f=448386
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Step 3 & 4: Rank remaining control technologies and evaluation of impacts

Based on the discussion in Steps 1 and 2, the technically feasible control options for GHGs from the 

emergency generators and the natural gas fuel heater are energy efficiency through the regulation of fuel 

use of a cleaner fuel (for non-emergency equipment), and limitation of the operating hours. There are no 

anticipated adverse environmental impacts associated with the use of these controls as BACT. 

Step 5: Select BACT

The emergency generator and the natural gas fuel heater together account for less than one percent of the 

total GHG emissions potential of the Project. The operation of these units will be regulated: emergency 

generator will follow work practice standards as their BACT and the natural gas fuel heater will be 

limited to operate for a maximum of 6,780 hours per year. Given the limited use of the emergency 

generator and the relatively small amount of GHG emissions, the EPA has determined that for the 

emergency generator work practice standards is more appropriate than a numeric BACT limit.

Furthermore, the operation of this unit will be limited to 100 hours, excluding emergencies per 40 CFR 

60 Subpart IIII and 40CFR 63 Subpart ZZZZ.

On the contrary, the EPA determined that for the natural gas fuel heater the proposed long-term BACT 

emission limit (in TPY on a 12-month rolling average) is more appropriate than a short-term emission 

limit. See Table 6-3 below for the proposed BACT. Compliance with these limits will be shown by 

following 40 CFR Part 98 methodologies, tracking the fuel consumption and hours of operation, as 

appropriate. Furthermore, to reduce the emissions and maintain consistency with the emission estimates 

in the permit application, the permit proposes to limit the use of these combustion units as described 

below.

Table 6-3 Proposed BACT for Smaller Combustion Equipment

Emission Unit Proposed BACT BACT Limit 

(TPY CO2e) Operating Limit

2.5 MW Emergency 

Generator (EU 007)

Selection of an energy efficient 

engine

Limitation on hours of operation

Work Practice 

Standards

Non-BACT limitation:

100 hours per 12-month 

rolling total (40 CFR 63 

Subpart ZZZZ)

Natural Gas Fuel 

Heater (EU 008)

Selection of an energy efficient 

heater

Limitation of hours of operation

Exclusive use of natural gas as 

fuel

3,965 6,780 hours per 12 month 

rolling average

6.3 GHG BACT Analysis for Circuit Breakers

Step 1: Identify all available control technologies

The applicant identified alternative (non-SF6) dielectric fluids, minimization of SF6, and good 

operational practices as the available control techniques in their permit application for the proposed 

circuit breakers. Historically, dielectric fluids such as dielectric oils have been used in high voltage 

applications. However, the use of these materials in circuit breakers has been predominantly replaced 

with SF6, which has superior dielectric and arc quenching properties. Modern SF6 circuit breakers are 
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PSD-EPA-R4013

designed as totally enclosed pressure systems with low potential SF6 fugitive emissions. The proposed 

circuit breaker will have a pressure gage with internal set points for operation limitations. Leakage is 

typically guaranteed to be no more than 0.5% by weight. In addition, circuit breakers have density 

alarms that provide warnings when a leak occurs. Further, this equipment is routinely inspected to insure 

proper operation since the equipment is necessary for safe operation of the Project.

Step 2: Eliminate technically infeasible control options

Circuit breakers using SF6 with alarms and periodic inspection are technically feasible for the Project. 

The use of alternative dielectric fluids is not practical for high voltage applications. Circuit breakers 

using SF6 insulating gas are presently superior in their performance to alternative systems using

dielectric oil, high pressure air blast, or vacuum circuit breakers. 

Step 3 & 4: Rank remaining control technologies and evaluation of impacts

Based on the discussion in Steps 1 and 2, the only technically feasible control option for SF6 emissions 

from circuit breakers is the use of modern enclosed systems with alarms and periodic inspection. There 

are no anticipated adverse environmental impacts associated with the use of modern enclosed circuit 

breaker systems with alarms and periodic inspection.

Step 5: Select BACT

The most effective control of fugitive SF6 emissions is using three totally enclosed systems equipped 

with leak detection along with good operational practices such as:

 Pressure gages with internal set points for operation limitations,

 Repair of leaks or replacement of equipment, and

 Continuous monitoring of circuit breaker pressure gage, periodic inspection, and maintenance.

Since emissions of GHGs from the circuit breakers ideally should be zero in the absence of leakage, the 

EPA has also proposed BACT to be work practice standards to minimize leakage. This includes the use 

of the proposed leak detection and periodic inspection and maintenance practices.

6.4 GHG BACT Analysis for GHG Fugitive Emissions from On-Site Pipeline

Step 1: Identify all available control technologies

The applicant did not identify any control technologies for fugitive GHG emissions related to leaks from 

on-site pipeline and natural gas supply. Nonetheless, the only feasible control technology for such 

emissions would be:

1. Minimize Leaks

Step 2: Eliminate technically infeasible control options

There are no technically infeasible control technologies to be eliminated.
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PSD-EPA-R4013

Step 3 & 4: Rank remaining control technologies and evaluation of impacts

Based on the discussions in Steps 1 and 2, the only technically feasible control option is to minimize 

natural gas leaks from piping components.

Step 5: Select BACT

The EPA agrees with the proposed BACT to minimize GHG fugitive emissions from on-site pipeline 

and natural gas supply through monitoring and repairing. The applicant will continuously monitor 

pipeline system pressure against alarm set points to identify leaks. Additionally, natural gas will be 

treated with mercaptan for human detection of any odor from leaks.

[THIS SPACE WAS INTENTIONALLY LEFT BLANK]
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7.0 Additional Requirements

7.1 Endangered Species Act 

Section 7(a)(2) of the Endangered Species Act (ESA) requires federal agencies, in consultation with the 

National Oceanic and Atmospheric Administration (NOAA) National Marine Fisheries Service (NMFS) 

and/or the U.S. Fish and Wildlife Service (FWS) (collectively, “the Services”), to ensure that any action 

authorized, funded, or carried out by the agency is not likely to jeopardize the continued existence of a 

species listed as threatened or endangered, or result in the destruction or adverse modification of 

designated critical habitat of such species. See 16 U.S.C. §1536(a)(2); see also 50 CFR §§ 402.13 and 

402.14. The federal agency is also required to confer with the Services on any action which is likely to 

jeopardize the continued existence of a species proposed for listing as threatened or endangered or 

which will result in the destruction or adverse modification of critical habitat proposed to be designated 

for such species. See 16 U.S.C. §1536(a)(4); see also 50 CFR 402.10. Further, the ESA regulations 

provide that where more than one federal agency is involved in an action, the consultation requirements 

may be fulfilled by a designated lead agency on behalf of itself and the other involved agencies. See 50 

CFR § 402.07. 

On December 3, 2012, NOAA’s NMFS Southeast Region, Habitat Conservation Division determined in 

an email response sent to the applicant, resources affected by the project for which the NMFS is 

responsible.

Based upon the best available data and informal consultation with the Services, the EPA determined that 

the issuance of this permit to Shady Hills is not likely to cause any adverse effects on listed species and 

essential fish habitats. The applicant will enforce standard protection measures during construction to 

ensure one of the potentially identified endangered species is not harmed. The proposed permit includes 

a condition requiring Shady Hills to comply with all other applicable federal regulations. The EPA 

received concurrence on November 27, 2012, from the Fish and Wildlife Service that the proposed 

project is not likely to adversely affect resources protected by the Endangered Species Act of 1973, as 

amended (16 U.S.C. 1531). The FWS confirmed the ESA consultation requirements were met.

7.2 Essential Fish Habitat of Magnuson-Stevens Act

Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and Management Act (MSFCA) 

requires federal agencies to consult with NOAA with respect to any action authorized, funded, or 

undertaken by the agency that may adversely affect any essential fish habitat identified under the MSA. 

The EPA is the lead agency for ESA Section 7 and MSA compliance for the Project and is currently in 

consultation with NOAA regarding both Acts (see ESA discussion above).

On August 2, 2013, the U.S. Department of Commerce, National Marine Fisheries Service (NMFS) 

confirmed, in an email, the EPA’s assessment that due to the location of the Shady Hills site, the Project 

will not likely affect any essential fish habitat according to the MSFCA.

7.3 National Historic Preservation Act

Section 106 of the National Historic Preservation Act requires federal agencies to take into account the 

effects of their undertakings on historic properties. Section 106 requires the lead agency official to 
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ensure that any federally funded, permitted, or licensed undertaking will have no effect on historic 

properties that are on or may be eligible for the National Register of Historic Places. 

A desktop cultural resource analysis was submitted to the Florida Division of Historical Resources

(DHS) by Golder Associates, Inc through a letter dated August 17, 2012. The Shady Hills property is 

approximately 30 acres, with the proposed generators and switchyard to be located east of the existing 

infrastructure. The area had been previously used as a construction laydown area. The survey included a 

review of information from the Florida Master Site File (FMSF). The survey determined that there are 

no previously recorded archaeological sites or historic standing structures within the Shady Hills

Generating Station property.

In a response letter dated September 20, 2012, the Florida DHS indicated that due to environmental 

conditions consistent with those found at other archaeological sites in Pasco Country and lack of 

professional archeological or historical investigation, there is some potential for undiscovered sites to 

occur. The DHR requested a special condition if historical or archaeological artifacts are discovered 

during construction, the EPA and FDEP will be notified and proper procedures will be followed.

7.4 Coastal Zone Management Act

According to the Coastal Zone Management Act of 1972 (CZMA), the State may develop and adopt a 

management program for its coastal zone in accordance with Federal rules and regulations promulgated 

by the Secretary, after notice, and with the opportunity of full participation by relevant Federal agencies, 

State agencies, local governments, regional organizations, port authorities, and other interested parties 

and individuals, public and private, which is adequate to carry out the purposes of the CZMA and is 

consistent with the policy declared in the CZMA.

The Florida Coastal Management Act (§380.205-380.27, Florida Statutes) requires that the Coastal Zone 

Management Section of FDEP be responsible for certification of consistency with the Florida Coastal 

Management Program (FCMP) for all Federal licenses, permits, activities, and projects listed in 

§380.23(3)(c), Florida Statutes, when such activities are subject to Federal consistency review and affect 

land or water use, are seaward of the jurisdiction of the state, or there is no State agency with sole 

jurisdiction for such consistency review. The issuance of Federal permits listed in §380.23(3)(c), Florida 

Statutes is not required.

NOAA’s NMFS, Southeast Region, Habitat Conservation Division determined in an email response sent 

to the applicant on December 3, 2012, that the resources affected by the project are not ones for which 

the NMFS is responsible since this type of Project is not included in the §380.23(3)(c), Florida Statutes.

7.5 Executive Order 12898 - Environmental Justice

Executive Order (EO) 12898 (59 FR 7629 (Feb. 16, 1994)) establishes federal executive branch policy 

on environmental justice. Based on this Executive Order, the EPA’s Environmental Appeals Board 

(EAB) has held that environmental justice issues must be considered in connection with the issuance of 

federal Prevention of Significant Deterioration (PSD) permits issued by the EPA Regional Offices [See, 

e.g., In re Prairie State Generating Company, 13 E.A.D. 1, 123 (EAB 2006); In re Knauf Fiber Glass, 

Gmbh, 8 E.A.D. 121, 174-75 (EAB 1999)]. This permitting action, if finalized, authorizes emissions of 

GHG, controlled by what we have determined is the Best Available Control Technology for those 

emissions. It does not select environmental controls for any other pollutants. Unlike the criteria 

pollutants for which the EPA has historically issued PSD permits, there is no National Ambient Air 
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Quality Standard (NAAQS) for GHG. The global climate-change inducing effects of GHG emissions, 

according to the “Endangerment and Cause or Contribute Finding”, are far-reaching and multidimensional (75 FR 66497). Climate change modeling and evaluations of risks and impacts are typically 

conducted for changes in emissions that are orders of magnitude larger than the emissions from 

individual projects that might be analyzed in PSD permit reviews. Quantifying the exact impacts 

attributable to a specific GHG source obtaining a permit in specific places and points would not be 

possible [PSD and Title V Permitting Guidance for GHGs at 48]. Thus, we conclude it would not be 

meaningful to evaluate impacts of GHG emissions on a local community in the context of a single 

permit. Accordingly, we have determined an environmental justice analysis is not necessary for the 

permitting record.

7.6 Executive Order 13175 – Tribal Consultation

In accordance with Executive Order 13175 and the EPA Policy on Consultation and Coordination with 

Indian Tribes, the Miccosukee Tribe of Indians of Florida (Miccosukee Tribe) and the Seminole Tribe of 

Florida (Seminole Tribe) were offered the opportunity to consult regarding the EPA’s consideration of 

the PSD permit application submitted by Shady Hills. Neither tribe responded to the EPA invitation for 

consultation sent on November 30, 2012, about the SHGS permit action. The EPA sent a letter 

confirming their lack of response on January 23, 2013. Both tribes were informed that regardless of 

whether they elected to consult on the permit application, they would also have the opportunity to 

submit comments during any forthcoming public comment period. 

The objective of such consultation, in the EPA’s view, is to improve the EPA’s understanding of the 

perspectives of the Seminole Tribe and Miccosukee Tribe and to identify any issues or concerns they 

may have regarding the EPA’s consideration of Shady Hills’s application. During the course of any 

consultation on this matter, the EPA can offer such things as education and outreach, holding conference 

call(s) to discuss issues and concerns, and providing feedback through written communication 

explaining how the EPA considered any issues and concerns raised.

[THIS SPACE WAS INTENTIONALLY LEFT BLANK]
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8.0 Public Participation

8.1 Opportunity for Public Comment

These proceedings are subject to the EPA’s Procedures for Decisionmaking, set forth at 40 CFR Part 

124. As provided in Part 124, EPA is seeking public comment on the Project draft air permit (PSD-EPAR4013) during the public comment period as specified in the public notice. 

Any interested person may submit written comments on the draft permit during the public comment 

period. If you believe that any condition of the permit is inappropriate, you must raise all reasonably 

ascertainable issues and submit all reasonably available arguments supporting your position by the end 

of the comment period. Any documents supporting your comments must be included in full and may not 

be incorporated by reference unless they are already part of the record for this permit or consist of state 

or federal statutes or regulations, EPA documents of general applicability, or other generally available 

referenced materials. 

Comments should focus on the proposed air quality permit and the GHG permit terms. Comments 

related to the other criteria pollutants and the preconstruction permitting under the jurisdiction of the 

State of Florida are outside the scope of this action. All timely comments will be considered in making 

the final decision, included in the record, and responded to by the EPA. The EPA may summarize the 

comments and group similar comments together in our response, and will not respond to individual 

commenters directly. 

All comments on the draft permit must be received by e-mail at R4GHGPermits@epa.gov, submitted 

electronically via www.regulations.gov (docket number EPA-R04-OAR-2013-0647), or postmarked by 

October 24, 2013. Comments sent by mail should be addressed to: USEPA Region 4, Air Permits 

Section, APTMD; 61 Forsyth Street, SW; Atlanta, GA 30303. An extension of the 30-day comment 

period may be granted if the request for an extension adequately demonstrates why additional time is 

required to prepare comments. Comments must be sent or delivered in writing to the address below. All 

comments will be included in the public docket without change and may be made available to the public, 

including any personal information provided, unless the comment includes Confidential Business 

Information or other information in which disclosure is restricted by statute. Information that you 

consider Confidential Business Information or otherwise protected should be clearly identified as such 

and should not be submitted through e-mail. If you send e-mail directly to the EPA, your email address 

will be captured automatically and included as part of the public comment. Please note that an e-mail or 

postal address must be provided with your comments if you wish to receive direct notification of the 

EPA’s final decision regarding the permit and the EPA’s response to comments submitted during the 

public comment period. 

For general questions on the draft permit, please contact: Mrs. Ana M. Oquendo at 404-562-9781 or 

oquendo.ana@epa.gov.

8.2 Public Hearing 

The EPA will hold a public hearing if the Agency determines there is a significant degree of public 

interest in the draft permit. Public hearing requests must be in writing and received by the EPA by email 

or mail by October 8, 2013. Requests should be sent by e-mail to R4GHGPermits@epa.gov or by mail 

addressed to: USEPA Region 4, Air Permits Section, APTMD; 61 Forsyth Street, SW; Atlanta, GA
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30303. Requests for a public hearing must state the nature of the issues proposed to be raised in the 

hearing. If a public hearing is held, you may submit oral and/or written comments on the draft permit at 

the public hearing. You do not need to attend the public hearing to submit written comments. If the EPA 

determines there is a significant degree of public interest, the EPA will hold a public hearing on the draft 

PSD permit on October 24, 2013, at the location given in the public notice. If a public hearing is held, 

the public comment period will automatically be extended to the close of the public hearing. If no 

timely request for a public hearing is received, or the EPA determines that there is not a significant 

degree of public interest, the hearing will be cancelled. An announcement of cancellation will be posted 

on the EPA’s website at: http://www.epa.gov/region4/air/permits/ghgpermits/ghgpermits.html, or you 

may call the EPA at the contact number above to determine if the public hearing will be held.

8.3 Administrative Record

The administrative record contains the application, supplemental information submitted by Shady Hills, 

and correspondence, including e-mails, between Shady Hills and its consultants and the EPA clarifying 

various aspects of Shady Hills application. The draft permit and the administrative record are available 

for public review at the EPA Region 4 office and the Regency Park Library at the addresses listed 

below. Please call in advance for available viewing times.

Regency Park Library

9701 Little Road

Port Richey, FL 34654

(727) 861-3049

EPA Region 4 Office

61 Forsyth Street, SW

Atlanta, GA 30303

Phone: (404) 562-9781

The administrative record and draft permit are also available on the EPA’s website at: 

http://www.epa.gov/region4/air/permits/ghgpermits/ghgpermits.html.

To request a copy of the draft permit, preliminary determination or notice of the final permit action, 

please contact: Ms. Rosa Yarbrough, Permit Support Specialist at: 404-562-9643, or 

R4GHGpermits@epa.gov.

8.4 Final Determination 

A decision to issue a final permit, or to deny the application for the permit, shall be made after all timely 

comments have been considered. Notice of the final decision shall be sent to each person who has 

submitted written comments or requested notice of the final permit decision, provided the EPA has 

adequate contact information.