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U.S. Environmental Protection Agency

Responses to Public Comments

Draft Greenhouse Gas PSD Air Permit for the New Hope Power Company–

Okeelanta Cogeneration Plant Boiler D Project

March 17, 2014
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Table of Contents

I. Introduction.......................................................................................................................3

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

Comments Submitted by Golder Associates ..............................................................3
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I. Introduction

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

Significant Deterioration (PSD) permit for Greenhouse Gases to New Hope Power Company (NHPC) 

for the Okeelanta Cogeneration Plant Boiler D Project (Project) on January 23, 2014. The public 

comment period for the proposal (Proposed Permit) began on January 23, 2014, and closed on February 

24, 2014.

EPA announced the public comment period through a public notice published in The Sun, The Clewiston 

News and The Glades (in English) on January 23, 2014, and on Region 4’s website (in English) on 

January 23, 2014. EPA also distributed the public notice to the necessary parties in accordance with 40 

CFR Part 124, including notices sent by email on January 23, 2014. Parties notified by EPA included 

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

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

through other means) from parties seeking notification regarding permit actions in Florida, within the 

jurisdiction of Florida Department of Environmental Protection (FDEP), within Palm Beach County, and 

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

During the public comment period, EPA received one comment letter and no requests for public hearing. 

Responses to the public comments received are available in the following section of this document.

II. EPA’s Responses to Public Comments

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

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

accessed online at http://www.regulations.gov (Docket #EPA-HQ-OAR-2014-0023) or on Region 4’s 

website at http://www.epa.gov/region4/air/permits/ghgpermits/ghgpermits.html. Although the 

commenter did not number their comments, EPA has done so in this document for clarity and ease of 

reference.

Comments Submitted by Golder Associates:

Comment 1:

Page 2. Project Location. 

It is requested that the description of the location be changed as follows: 

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. 

Please also note that the first paragraph of the Public Notice stated in error that the plant is located 

“within the City of South Bay”. 

Page 2. Project Description. 

The project description states: 

The facility currently operates two cogeneration boilers that combust primarily biomass (bagasse and 

wood), and one natural gas boiler to generate steam and electricity (Boilers A, B and C). 

This description is inaccurate; biomass is the primary fuel used in all three of NHPC’s boilers. Recently, 

Boiler A was permitted to fire natural gas in addition to biomass and No. 2 fuel oil; however, biomass 

remains the primary fuel in Boiler A. It is requested that the project description be changed as follows: 
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The facility currently operates two three cogeneration boilers that combust primarily biomass (bagasse 

and wood), and one natural gas boiler to generate steam and electricity (Boilers A, B and C).

Response 1:

EPA acknowledges the need for these corrections. The permit has been revised. See EPA’s 

redline/strikeout version of the permit for all changes.

Comment 2:

Page 6. IX. Special Conditions. B.2. 

EPA has proposed GHG emission limits of 157 lb CO2e per 1,000 lbs steam produced as a 30- day 

rolling average for natural gas firing, and 218 lb CO2e per 1,000 lbs steam produced as a 30- day rolling 

average for No. 2 fuel oil firing. Although no derivation of these numbers is found in the permit or 

Preliminary Determination, they appear to be based on calculations presented in NHPC’s application, 

but EPA’s calculations fail to provide any margin for vendor guarantees or degradation of the boiler’s 

efficiency over time. The calculation for natural gas is: 

CO2 emission factor = 53.02 kg/MMBtu 

CH4 emission factor = 0.001 kg/MMBtu x 25 = 0.025 kg/MMBtu 

N2O emission factor = 0.0001 kg/MMBtu x 298 = 0.0298 kg/MMBtu 

Total CO2e emission factor = 53.0748 kg/MMBtu x (1000 / 453.59) = 117.02 lb/MMBtu 

Boiler D heat input = 536 MMBtu/hr @ 400,000 lb/hr steam 

Boiler D mass CO2e emissions = 536 MMBtu/hr x 117.02 lb/MMBtu = 62,723 lb/hr CO2e 

Boiler D CO2e emissions = 62,723 lb/hr CO2e / 400 klbs/hr steam = 157 lb CO2e per 1,000 lbs steam 

produced 

NHPC requested that a margin be provided to account for the difference between the vendor’s 

guarantees and boiler’s actual heat rate, as well as the degradation in boiler efficiency that will occur 

over time. In NHPC’s response (Golder Associates, Inc., letter dated May 17, 2013) to EPA’s Notice of 

Incompleteness (dated March 8, 2013), NHPC explained the reasoning for requesting these margins. 

As shown in NHPC’s GHG PSD permit application, there have been very few GHG determinations 

issued by EPA for natural gas-fired boilers. The determinations that have been issued have set GHG 

emission limits in terms of lb CO2e/MMBtu heat input. NHPC does not object to a GHG limit based on 

heat input (i.e., 117 lb CO2e/MMBtu heat input). Basing the GHG limit in these terms does not involve 

margins for degradation or vendor guarantees, because the limit is based strictly on heat input. 

EPA provides margins when issuing GHG PSD permits for natural gas fired combined cycle power 

plants where the GHG emission limits are based on the facility’s output. For instance, EPA recently 

issued a final permit for the Shady Hills power plant, and EPA provided an 8% margin of compliance in 

the GHG emission limits. This margin for compliance was based on “a 3 percent margin for the 

difference between guaranteed heat rates and actual heat rate, and a 5 percent margin for degradation 

over time”. [refer to Preliminary Determination & Statement of Basis for Permit PSD-EPA-R4013, 

issued 9/23/2013, pg. 19, attached]. At a minimum, the draft permit for the NHPC facility should be 

revised to provide margins of compliance at least as large as those provided to the Shady Hills facility. 

EPA’s draft permit for the NHPC facility also should be revised because it appears that EPA’s proposed 

emission limits for the NHPC facility do not exclude GHG emissions that occur during periods of 

startup, shutdown and malfunction (SSM). During periods of startup and shutdown, unit efficiency is 

likely to be less than design, due to boiler components and auxiliaries heating up, low steam output, and 

limited or no electrical generation. Therefore, GHG emissions during these periods should be excluded 
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from the emission limit. In the alternative, the proposed emission limits for GHG should be adjusted 

upward to account for the SSM events.

As a practical matter, however, this latter approach would be very difficult to implement because it is 

difficult, if not impossible, to predict the number and duration of SSM events, and the operating 

conditions during such events. 

In EPA’s recent proposal to limit GHG emissions from electric utility generating units, EPA states “In 

proposing the standards in this rule, EPA has taken into account startup and shutdown periods. . . .” 

[Federal Register, Vol. 79, No. 5, January 8, 2014, pg.1448] This statement implies that EPA adjusted 

the proposed standards appropriately to account for either lower or higher emissions of GHG during 

startup and shutdown events (i.e., measured on a lb/MW-hr basis). The same approach should be used to 

adjust the GHG emission limits for the proposed NHPC boiler, or these events should be excluded from 

the compliance determination. 

NHPC does not have actual CO2e emissions data for its proposed boiler during startup/shutdown 

periods because NHPC’s boiler has not yet been built. Nonetheless, it is appropriate to include a margin 

to account for such events when setting the GHG emission limit for NHPC’s boiler. In NHPC’s original 

GHG application, a total margin of 10 percent was proposed. NHPC continues to believe this margin is 

necessary and appropriate to account for all of the factors described above. 

Therefore, NHPC requests that the GHG emission limits for Boiler D be revised as follows: 

Natural gas- 157 lb CO2e x 1.1 = 173 lb CO2e per 1,000 lbs steam produced 

No. 2 Fuel Oil- 218 lb CO2e x 1.1 = 240 lb CO2e per 1,000 lbs steam produced 

Response 2:

EPA agrees that, while the detailed calculations for the numerical emission limitations were not included 

in the permit documents, they were derived from the emission factors given in the application in a 

similar manner to the calculation method presented by the commenter. Also included in the emission 

estimate calculations provided by the applicant was a figure of 85% thermal efficiency which was relied 

upon by EPA to arrive at the BACT emission limits for Boiler D. Regarding the commenter’s request to 

include a “margin of compliance,” EPA agrees that previous permits have included margins of 

compliance. However, based on guidance provided in EPA’s Climate Leaders Greenhouse Gas 

Inventory Protocol Offset Project Methodology for Industrial Boiler Efficiency (Industrial Process 

Applications), August 20081, EPA believes the 85% thermal efficiency figure used to calculate the PSD 

limitations takes into account any variability and boiler degradation margin that may be needed.

Specifically, based on the minimum design characteristics of the applicant’s proposed boiler and 

proposed energy efficiency measures (e.g., use of an economizer and blowdown heat recovery), the 

above referenced guidance indicates a thermal efficiency of 89% is achievable. Consequently, 

establishing Boiler D’s BACT limits based on an 85% efficiency provides a 4% margin of compliance 

for heat rate variability and boiler degradation. 

EPA acknowledges the commenter’s statements regarding the discussion in the preliminary 

determination and statement of basis for the Shady Hills facility. The Shady Hills facility took a 

limitation of 3,390 hours of operation, and will be an intermittently operating (peaking) electric plant

with frequent startup and shutdown events planned and separate BACT limits associated with such 

events. In contrast, Boiler D has been proposed to operate 8760 hours a year, primarily providing 

process steam regardless of whether electrical generation is a byproduct or not. Due to the difference in 

 

1 http://www.epa.gov/climateleadership/documents/resources/industrial_boiler_protocol.pdf
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the operating scenarios of Shady Hills and NHPC’s Boiler D, EPA does not view the Shady Hills project 

as an appropriate comparison. Thus, EPA believes a 4% margin is appropriate for the New Hope project, 

since it is expected to have far fewer startup and shutdown events than a peaking turbine facility (e.g.,

Shady Hills). Furthermore, the applicant did not submit as part of the application or supplemental 

information any data estimating SSM events or emissions information justifying the need for a 10% 

margin of compliance, as requested in the comment. Additionally, the proposed 30-day averaging time 

associated with the use of natural gas (primary fuel) will also provide flexibility for any possible SSM 

events. As discussed above and in the referenced EPA guidance for boilers, the thermal efficiency figure 

of 85% takes into consideration variability in heat rates and provides an ample margin of compliance 

without a change to the permit limits or minimum thermal efficiency limit. EPA will not revise the 

proposed BACT limits or thermal efficiency conditions in the draft permit, as requested by the 

commenter.

Comment 3:

Page 6. IX. Special Conditions. B.3. 

NHPC requests EPA to add a permitting note to this condition. The permitting note should state that 

NHPC has filed a petition for reconsideration and thereby requested EPA to revise 40 CFR Part 63, 

Subpart DDDDD in a manner which will exempt the NHPC boilers, including the proposed new natural 

gas-fired boiler, from the requirements in Subpart DDDDD. [see Golder Associates/NHPC’s letter to 

EPA dated May 17, 2013, pg. 2 (attached)]. Further, the permitting note should acknowledge that, if 

Subpart DDDDD does not apply to the NHPC facility, the limitation on fuel oil usage will be changed to 

an eight percent (8%) annual capacity factor, which is equivalent to 700 hours at the maximum fuel oil 

firing rate. EPA previously stated to NHPC that such a limitation would be sufficient to represent 

BACT. This information also should be stated in the Preliminary Determination & Statement of Basis. 

Response 3:

EPA acknowledges the NHPC petition for reconsideration regarding applicability of 40 CFR Part 63, 

Subpart DDDDD and it is so noted in this response to the commenter and will be included in the permit 

record. However, EPA has not stated that an 8% annual capacity factor or 700 hours of fuel oil “would 

be sufficient to represent BACT.” That statement is inaccurate. Currently, the permit allows the use of 

fuel oil for a maximum of 48 hours per 12-month rolling average and during periods of curtailment or 

gas supply interruption as defined in the applicable Subpart. In the event of a non-applicability 

determination of 40 CFR Part 63, Subpart DDDDD, the applicant would be able to apply for a 

modification to the permit for the related permit conditions. 

Comment 4:

Page 6. IX. Special Conditions. B.4. 

Condition B.4 is unnecessary and should be deleted. The thermal efficiency of the boiler will be 

inherently reflected in the GHG emission rate, which is expressed in pounds of CO2e/1,000 pounds of 

steam produced. If the boiler’s thermal efficiency declines, more fuel will be required to generate 1,000 

pounds of steam and, in turn, higher CO2e emissions will occur. Since Condition B.4 overlaps and in 

effect duplicates the requirements in Condition B.2, the thermal efficiency limitation in Condition B.4 

should be eliminated. 

If EPA chooses to retain the thermal efficiency limit, the thermal efficiency limit should be adjusted to 

provide a margin for compliance and thus account for the factors discussed above. Specifically, NHPC 

requests EPA to provide a 10 percent margin to the design thermal efficiency of the boiler and thereby 

account for the difference between the vendor guarantee and the boiler’s actual performance, as well as 
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the degradation of the boiler over time, and SSM events. The adjusted limit for thermal efficiency 

should be calculated as follows: 

85% / 1.1 = 77% thermal efficiency on a 30-day rolling average

Response 4:

See EPA’s response to comment #2. No change to the permit is necessary, as explained above.

Comment 5:

Preliminary Determination & Statement of Basis 

Page 3. Introduction. 

The project description states: 

The facility currently has two cogeneration boilers that combust primarily biomass (bagasse and wood), 

and one natural gas boiler to generate steam and electricity (Boilers A, B and C). 

As discussed previously, it is requested that the description be changed as follows: 

The facility currently has two three cogeneration boilers that combust primarily biomass (bagasse and 

wood), and one natural gas boiler to generate steam and electricity (Boilers A, B and C). 

Page 5. Proposed Project. 

3rd paragraph: “147.74 TPY of NOx” should be revised to read “140.74 TPY of NOx”. 

4th paragraph: As discussed above, a permitting note should be added to Condition B.3 of the permit, 

stating that NHPC has filed a petition for reconsideration with EPA and, if EPA determines Subpart 

DDDDD does not apply to the NHPC facility, then the limitation on fuel oil usage will be changed to an 

eight percent (8%) annual capacity factor (equivalent to 700 hours at the maximum fuel oil firing rate). 

Last paragraph: The text should be revised because Boiler A was not converted to natural gas. The 2012 

permit cited in the Preliminary Determination authorized the use of natural gas as a backup/auxiliary 

fuel, in addition to No. 2 fuel oil. Biomass continues to be the primary fuel used in Boiler A. 

Page 8. Table 5-1. 

The footnote to the table indicates that the PTE (TPY) is based on 100% natural gas firing. If this is the 

case, the following corrections should be made to Table 5-1: 

SO2 – 1.38 TPY (not 19.54). 

NOx - 140.74 TPY (not 147.74) 

Lead – 0.00115 TPY (not 0.18) 

Mercury – 1.2 lb/yr (not 6.5) 

Page 13. GHG BACT Analysis for Natural Gas Boiler 

For the reasons set forth above, NHPC requests that the GHG emission limits be revised. NHPC also 

requests that the minimum thermal efficiency requirement be deleted or revised.

Response 5:

EPA acknowledges receipt of the above comments related to the preliminary determination/statement of 

basis. Any necessary changes will be reflected appropriately in the redline/strikeout version of the 

permit (and summarized in the final determination) rather than a redline/strikeout version of the 

preliminary determination/statement of basis.

Regarding suggested corrections to Table 5-1, EPA acknowledges the typographical error contained in 

the table for the NOx PTE. With that exception, the PTE numbers included in Table 5-1 of EPA’s 

preliminary determination were taken from Table 4 on page 9 of the Florida Department of 

Environmental Protection’s Technical Evaluation and Preliminary Determination (dated June 24, 2013),
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entitled “APPLICANT’S PSD APPLICABILITY ANALYSIS (TPY)” which includes a footnote 

indicating the information was based on 100% natural gas usage in the boiler.