Y:\Projects\2012\123-87582 NHPC PSD\EPA RAI\Final\NHPC EPA RAI.docx

Golder Associates Inc.

6026 NW 1st Place

Gainesville, FL 32607 USA

Tel: (352) 336-5600 Fax: (352) 336-6603 www.golder.com

Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation

May 17, 2013 123-87582

Via Electronic Delivery

Ms. Kelly A. Fortin, Acting Chief, Air Permits Section

United States Environmental Protection Agency

Region 4

Atlanta Federal Center

61 Forsyth Street

Atlanta, Georgia 30303-8960

RE: RESPONSE TO NOTICE OF INCOMPLETENESS

PROPOSED NATURAL GAS BOILER

NEW HOPE POWER COMPANY OKEELANTA COGENERATION PLANT

Dear Ms. Fortin:

New Hope Power Company (NHPC) and Golder Associates Inc. (Golder) have received the notice of 

incompleteness (NOI) dated March 8, 2013, for the proposed new natural gas boiler at the Okeelanta 

cogeneration facility. The responses to the comments made in the NOI are addressed below, in the same 

order as they appear in the NOI.

Comment 1. The application addresses the Project’s applicability to the Endangered Species 

Act (ESA), the National Historic Preservation Act (NHPA), the Magnuson-Stevens 

Fishery Conservation and Management Act (MSFCMA), and the Coastal Zone 

Management Act (CZMA). Please provide the status of any assessments performed 

and/or communications with the appropriate federal agencies (other than the 

efforts already noted in your application).

Response: The list below includes the federal agencies contacted and the status of the agencies’

determinations:

 National Park Service (NPS): Based on the proposed emission increases and the 

distance from Everglades National Park, the NPS does not anticipate that air 

quality related values (AQRVs) will be adversely affected in this park. Therefore, 

the NPS is not requesting that the applicant complete a Class I AQRV modeling 

analysis (see attached email from Andrea Stacey, NPS Air Resource Division, 

dated March 6, 2013). This determination by the NPS concludes their assessment

of the project’s applicability to the NHPA.

 U.S. Fish & Wildlife Service (USFWS): The U.S. Environmental Protection Agency

(EPA), USFWS, and NHPC participated in a teleconference on April 9, 2013 

discussing the effect, if any, the project will have on endangered or threatened 

species in the project area, including everglades snail kite, endangered wood 

stork, threatened northern crested caracara, and threatened eastern indigo 

snake. Based on the teleconference discussion, the EPA will make a “no effect”

determination for the project, and the USFWS will issue a concurrency response 

to the EPA’s determination; therefore, the proposed project will not affect any 

endangered or threatened species. This determination by EPA and USFWS 

concludes the assessment of the project’s applicability to the ESA.
Ms. Kelly A. Fortin May 17, 2013

U.S. Environmental Protection Agency 2 123-87582

Y:\Projects\2012\123-87582 NHPC PSD\EPA RAI\Final\NHPC EPA RAI.docx

 National Oceanic and Atmospheric Administration (NOAA)/National Marine 

Fisheries Service (NMFS): Per a telephone conversation on February 26, 2013 

with David Bernhart, Assistant Regional Administrator of Protected Resources 

Division, NOAA/NMFS is waiting on the EPA’s determination before proceeding.

If the EPA determines the project has “no effect” on the marine resources 

NOAA/NMFS is concerned about, the project does not need concurrence from 

NOAA. If the EPA determines the project “may affect” marine resources, there 

will need to be consultation with NOAA. As stated by the USFWS during the 

April 9, 2013 teleconference, the project will not affect marine resources due to 

the project’s distance from the nearest seacoast (approximately 40 miles). The 

EPA’s determination of “no effect” will conclude the assessment of the project’s 

applicability to the MSFCMA and CZMA.

Comment 2. It is our understanding that this project is potentially subject to 40 CFR 63 

Subpart DDDDD, which may result in the change in amount of proposed fuel oil 

use for the boiler. If this NESHAP does apply, please identify the requirements, 

define the expected fuel use scenarios, and provide any necessary revisions to the 

PSD permit application as a result from the revised fuel use (e.g., emissions 

calculations and proposed BACT limit).

Response: It has not yet been determined whether the proposed Boiler D at NHPC will be subject to 

40 CFR 63 Subpart DDDDD (Boiler MACT). The existing boilers at the NHPC facility fit within EPA’s 

definition of an electric generating unit (EGU). Likewise, the proposed Boiler D will fit within the definition 

of an EGU. Prior to 2013, all of the proposed and final versions of the Boiler MACT provided that EGUs, 

like the ones at the NHPC facility, are not subject to the Boiler MACT rule. However, in the final rule 

published on January 31, 2013, the exemption for EGUs was changed. Under the 2013 final rule, EGUs 

are exempt from the Boiler MACT only if the EGUs are “covered by” 40 CFR 63 Subpart UUUUU, which 

covers only coal- and oil-fired EGUs. The existing EGUs at the NHPC Facility are not “covered by 

Subpart UUUUU”, and neither will the proposed Boiler D.

NHPC recently filed a petition requesting EPA to reconsider its recent changes to its exemption for EGUs.

Specifically, NHPC requested EPA to retain the former exclusion under Subpart DDDDD for all EGUs, not 

just those “covered by Subpart UUUUU”. The Utility Air Regulatory Group (UARG) also filed a petition 

requesting EPA to reconsider this issue. It is unclear when EPA will rule on the merits of NHPC’s petition.

In the event that the proposed Boiler D is determined to be subject to Boiler MACT, NHPC will accept 

federally enforceable operating limits so that the proposed boiler will be classified and regulated under 

Boiler MACT as a “unit designed to burn gas 1”. Accordingly, fuel oil will not be burned for more than 

48 hours during any calendar year, except during periods of gas curtailment or gas supply interruptions of 

any duration. This classification will not change any of the proposed BACT limits for the proposed Boiler D.

If it is determined that Boiler MACT will not be applicable to the proposed natural gas-fired boiler, NHPC 

would like to retain the flexibility to burn natural gas as well as fuel oil up to the 10 percent and 15 percent 

thresholds, as stated in NHPC’s application.

Comment 3. Appendix A provides factors and some calculations used to derive the proposed 

GHG best available control technology (BACT) limits contained in the application. 

A CO2 emission factor is given, however, the basis for this, and other assumptions 

used in Appendix A, was not found. Please provide the basis for these calculations 

and assumptions, and please include complete emissions calculations for the 

planned operating scenarios of the proposed natural gas fired boiler (Boiler D).

Response: The proposed BACT limits were derived using design data for the proposed Boiler D as 

well as operational data for the NHPC boilers and electrical generators and steam supplied to the 

Okeelanta sugar mill. An explanation of the information provided in Appendix A of the GHG application is 
Ms. Kelly A. Fortin May 17, 2013

U.S. Environmental Protection Agency 3 123-87582

Y:\Projects\2012\123-87582 NHPC PSD\EPA RAI\Final\NHPC EPA RAI.docx

presented below. To determine a GHG emission limit in terms of pounds per megawatt-hour (lb/MW-hr), it 

is necessary to determine the total MW-hr output from Boiler D due to both electrical generation and 

useful thermal energy.

Boiler D Design Data:

Steam Production

Maximum 1-hour: 440,000 lb/hr steam

Maximum 24-hour: 400,000 lb/hr steam

Steam Enthalpy

Steam Conditions: 1,500 psig, 905°F = 1,515 psia, 905°F, Enthalpy = 1,460 Btu/lb

Feedwater Conditions: 1,349 psig, 350°F = 1,364 psia, 350°F, Enthalpy = 322 Btu/lb

Net Enthalpy: 1,460 Btu/lb – 322 Btu/lb = 1,138 Btu/lb steam

Heat Input Calculation (based on 85 percent thermal efficiency for natural gas or No. 2 fuel oil)

Maximum 1-hour: 440,000 lb/hr steam x 1,138 Btu/lb x 1/0.85 = 589 MMBtu/hr

Maximum 24-hour: 400,000 lb/hr steam x 1,138 Btu/lb x 1/0.85 = 535.5 MMBtu/hr

Annual Rate: 535.5 MMBtu/hr x 8,760 hr/yr = 4,691,238 MMBtu/yr

The CO2 emission factors for natural gas firing (53.02 kg/MMBtu) and for No. 2 fuel oil (73.96 kg/MMBtu) 

are from 40 CFR 98, Subpart C, Table C-1.

NHPC Operating Data:

Crop Season Operation – Natural Gas Firing

During the crop season, the NHPC boilers with the new Boiler D will generate nominally 70 MW 

of electricity from 1,200,000 lb/hr steam. Boiler D’s portion of this is 300,000 lb/hr (25%), or 

17.5 MW.

All boilers combined will send 270,000 lb/hr of high pressure steam to the Okeelanta sugar mill.

This is steam not used for additional electrical energy production. Boiler D’s portion of this will be 

25%, or 67,500 lb/hr. The net enthalpy of this steam will be 1,336 Btu/lb, which equates to 

90.2 MMBtu/hr.

All boilers combined will send 390,000 lb/hr of low pressure steam to the Okeelanta sugar mill.

This is steam not used for additional electrical energy production. Boiler D’s portion of this will be 

25%, or 97,500 lb/hr. The net enthalpy of this steam will be 1,177 Btu/lb, which equates to 

114.8 MMBtu/hr.

Therefore, the total useful thermal output from Boiler D will equate to 204.9 MMBtu/hr, or 60.1 MW

(204.9 x 0.2928). The total gross output of Boiler D is then the gross electrical output (17.5 MW) 

plus 75% of the thermal output (60.1 MW x 0.75 = 45.1), or 62.6 MW.

The CO2 emission rate based on 300,000 lb/hr steam for Boiler D (46,906 lb/hr) was then divided 

by the total gross output of 62.6 MW to obtain the final CO2 limit of 750 lb CO2/MW-hr.

The table in Appendix A then accounts for the margins for guarantee and degradation for the boiler.

Other Operating Scenarios

The lb/MW-hr limits for the other operating scenarios shown in Appendix A of the application were 

calculated in the same manner, considering off-season steam production, and No. 2 fuel oil firing.

Comment 4. Section 2.2.1.1 of the application discusses clean fuel options and states that 

natural gas is the lowest carbon content fossil fuel on a pound per British thermal 
Ms. Kelly A. Fortin May 17, 2013

U.S. Environmental Protection Agency 4 123-87582

Y:\Projects\2012\123-87582 NHPC PSD\EPA RAI\Final\NHPC EPA RAI.docx

unit (lb/Btu) basis. However, according to Appendix A, the proposed GHG BACT 

for Boiler D is the use of natural gas as the primary fuel and No. 2 fuel oil for up to 

15% of the operating hours. It is unclear whether 100-percent-utilization of natural 

gas was considered as a BACT option. If it was considered, what are the grounds 

for not selecting it and instead selecting a less clean fuel (i.e., No. 2 fuel oil) for 

partial operation? Please revise your application to address this discrepancy with 

your BACT analysis.

Response: In Section 2.2.5 of the application, GHG emission limits are presented for both natural 

gas firing and No. 2 fuel oil firing, as well as for crop season operation and for off-crop season operation.

The boiler will be fired primarily with natural gas, with No. 2 fuel oil as a backup fuel. NHPC is not 

proposing 100-percent firing of natural gas because NHPC desires to retain a backup fuel in the event 

that there is a curtailment or loss of the natural gas fuel supply. No. 2 fuel oil firing will be limited to no 

more than 15% on an annual heat input basis. Based on this limitation, it does not appear there is 

justification to further limit No. 2 fuel oil firing based on BACT.

Comment 5. Appendix A indicates the proposed GHG BACT emission limits for Boiler D were 

derived using a 85% of thermal efficiency number while assuming a 5% design 

margin and a 5% performance degradation margin. Please provide documentation 

or an explanation on how these margins were derived, why they are appropriate for 

the proposed boiler, and why boiler degradation is assumed even at the beginning 

of its use given the design thermal efficiency of 85% reflected in Section 2.2.5 

(page 11) of the application.

Response: NHPC has not yet selected the boiler manufacturer; therefore, no manufacturer’s design 

information is yet available. However, a 5 percent margin has been included to account for design standards

typical of construction contracts and equipment manufacturer’s supply contracts, which contain provisions 

for minimum acceptable performance criteria. These include the ability for the contractor/supplier to 

“buy-down” performance by paying liquidated damages if performance (in this case, unit heat rate) does 

not meet the levels guaranteed in the contract. A typical minimum acceptance threshold for heat rate may 

be up to 105 percent of the contractually guaranteed value, and thus a 5 percent margin for this component

of the compliance was used in the BACT limit calculation. Therefore, this margin was used for the proposed

boiler because it reflects market standard terms and conditions which are available in commercial 

contracts today. Boiler degradation is included in the compliance limit even at the very beginning of its 

use since the compliance limit is established as a single value over the lifetime of the boiler.

Boiler degradation occurs over time based on actual use of the unit, and is dependent on hours of 

operation, number of load changes, and start-up/shut-down cycles. Since the operation of the boiler will 

vary over time based on market conditions and plant steam demands, it is appropriate to include the 

degradation allowance in the compliance limits from the outset. The 5 percent value for boiler degradation 

margin reflects experience with similar boilers.

Comment 6. Section 2.2.5 states an oxygen or CO2 monitor will be installed on the boiler as part 

of a digital control system; however, the application has not proposed the use of a 

continuous emission monitoring system (CEMS) for monitoring of GHG emissions.

Please include further discussion to provide details regarding the suitability of the 

monitoring, recordkeeping and reporting proposed to ensure compliance with the 

GHG BACT limitations for all operating scenarios anticipated.

Response: CO2 CEMS is not warranted for the boiler because only natural gas and No. 2 fuel oil will 

be burned in the boiler. Use of the standard emission factors and standard heating values for these fuels 

would not result in substantially different CO2 emission rates than would result from continuous 

measurement of the CO2 emissions. Steam production and steam pressure and temperature will be 
Ms. Kelly A. Fortin May 17, 2013

U.S. Environmental Protection Agency 5 123-87582

Y:\Projects\2012\123-87582 NHPC PSD\EPA RAI\Final\NHPC EPA RAI.docx

measured continuously, as well as the amount of steam sent to the Okeelanta sugar mill, allowing the 

useful thermal output from the boiler to be monitored for input into the GHG emission rate calculations.

Therefore, a CO2 CEMS is not warranted.

Thank you for your consideration of this information. If you have any questions, please do not hesitate to 

call me at (352) 336-5600.

Sincerely,

GOLDER ASSOCIATES INC.

Philip D. Cobb, Ph.D., P.E. David A. Buff, P.E., Q.E.P.

Senior Project Engineer Principal Engineer

cc: Matt Capone

Attachments

PC/DB/tz
EMAIL FROM NPS AIR RESOURCE DIVISION

MARCH 6, 2013
1

Sealey, Kristen

From: Stacy, Andrea <andrea_stacy@nps.gov>

Sent: Wednesday, March 06, 2013 9:32 AM

To: Sealey, Kristen

Cc: Don Shepherd; Susan Johnson

Subject: Re: FW: PSD Greenhouse Gas Emissions Notification - New Hope Power Company, Florida

Kristen,

Thank you for submitting the following information regarding the New Hope Power Company’s Okeelanta 

Cogeneration Plant, located in Palm Beach County, Florida. New Hope is proposing to add a natural gas fired 

boiler to its 140 MW Electric Generating Unit. Based on the proposed emission increases and the distance 

from Everglades National Park, the NPS does not anticipate that air quality related values (AQRV) will be 

adversely affected in this park. Therefore, we are not requesting that the applicant complete a Class I AQRV 

modeling analysis. However, we are potentially interested in reviewing the GHG and criteria pollutant BACT 

analyses. Please advise us of the review time frame for these documents. We also request that you submit a 

copy draft permit and draft engineering analyses to the NPS when these documents become available. 

Please note that our determination regarding the need for a Class I AQRV analysis does not indicate our 

agreement with any Class I modeling protocols, results or conclusions that applicants might make independent 

of Federal Land Manager review. Furthermore, we are only addressing the need for an AQRV analysis in 

Everglades NP; independent determinations will need to be made for Class I areas managed by other federal 

agencies (i.e. FWS, USFS). The state and/or EPA may have a different opinion regarding the need for a Class 

I increment analysis. 

Finally, please contact me if the emissions or nature of the project change significantly so that the NPS may reevaluate the need for a Class I AQRV analysis. Thank you for involving the NPS in this project review, feel 

free to contact me if you have any questions. 

Regards,

Andrea Stacy 

On Tue, Feb 26, 2013 at 12:28 PM, Sealey, Kristen <Kristen_Sealey@golder.com> wrote: 

Hello Andrea,

Per your request, attached you will find the applications submitted to the EPA (Greenhouse Gas) and the FDEP 

(Prevention of Significant Deterioration). The FDEP application includes tables presenting the maximum 24-hour 

emissions for the various fuels. 

Thank you,
2

Kristen

 

Kristen Sealey | Project Engineer | Golder Associates Inc. 

6026 NW 1st Place, Gainesville, Florida, USA 32607 

T: +1 (352) 336-5600 | D: +1 (352) 224-1147 | F: +1 (352) 336-6603 | E: Kristen_Sealey@golder.com | 

www.golder.com 

Work Safe, Home Safe 

This email transmission is confidential and may contain proprietary information for the exclusive use of the intended recipient. Any use, distribution or copying of 

this transmission, other than by the intended recipient, is strictly prohibited. If you are not the intended recipient, please notify the sender and delete all copies. 

Electronic media is susceptible to unauthorized modification, deterioration, and incompatibility. Accordingly, the electronic media version of any work product may 

not be relied upon. 

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation. 

Please consider the environment before printing this email. 

 

From: Sealey, Kristen 

Sent: Thursday, February 07, 2013 3:31 PM 

To: andrea_stacy@nps.gov

Subject: FW: PSD Greenhouse Gas Emissions Notification - New Hope Power Company, Florida

 

Hello Ms. Stacy,

I’m following up to confirm you received the email below regarding the proposed boiler at New Hope, and that the project 

is in the queue for PSD GHG review. Can you send me an email confirming receipt of the project notification and provide 

an approximate timeframe for the review process? 

Thank you,

Kristen 

Kristen Sealey | Project Engineer | Golder Associates Inc. 

6026 NW 1st Place, Gainesville, Florida, USA 32607 

T: +1 (352) 336-5600 | D: +1 (352) 224-1147 | F: +1 (352) 336-6603 | E: Kristen_Sealey@golder.com | 

www.golder.com 

Work Safe, Home Safe 

This email transmission is confidential and may contain proprietary information for the exclusive use of the intended recipient. Any use, distribution or copying of 

this transmission, other than by the intended recipient, is strictly prohibited. If you are not the intended recipient, please notify the sender and delete all copies. 

Electronic media is susceptible to unauthorized modification, deterioration, and incompatibility. Accordingly, the electronic media version of any work product may 

not be relied upon. 

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation. 
3

Please consider the environment before printing this email. 

From: Sealey, Kristen 

Sent: Wednesday, January 30, 2013 4:10 PM 

To: 'andrea_stacy@nps.gov' 

Cc: Buff, Dave; Cobb, Phil 

Subject: PSD Greenhouse Gas Emissions Notification - New Hope Power Company, Florida

 

Hello Ms. Stacy, 

 

New Hope Power Company (NHPC) operates an electric cogeneration facility located adjacent to the Okeelanta 

Corporation sugar mill and refinery in Palm Beach County, Florida. NHPC is requesting authorization to add a natural 

gas-fired boiler to the facility. The new boiler will have a nominal steam generating capacity of 400,000-pound per hour 

(lb/hr), fired primarily by natural gas (No. 2 fuel oil as backup only), and will be permitted for 8,760 hr/yr operation. The 

construction of the new boiler requires prevention of significant deterioration (PSD) approval by U.S. EPA for emissions of 

greenhouse gases (GHG). Federal statutory requirements that may apply to the project are: 

 Endangered Species Act 

 Coastal Zone Management Act 

 National Historic Preservation Act 

 Magnuson-Stevens Fishery Conservation and Management Act 

 Federal Land Manager 

 

In addition, the project may affect PSD Class I areas (Everglades National Park)and other areas administered by the U.S. 

Fish and Wildlife Service. Indian tribal lands may also be affected. 

 

The attached fact sheet provides additional information on the project including a project description, a site map, emission 

tables, and air quality impact assessments as it relates to the aforementioned statutory requirements. We ask that you 

review this information to determine if the proposed project will comply with the rules and policies administered by your 

agency. 

 

Thank you in advance for your assistance with this PSD GHG review and approval. If you need additional information, 

please feel free to contact me by email or telephone at 352-336-5600. 

 
4

Kristen Sealey | Project Engineer | Golder Associates Inc. 

6026 NW 1st Place, Gainesville, Florida, USA 32607 

T: +1 (352) 336-5600 | D: +1 (352) 224-1147 | F: +1 (352) 336-6603 | E: Kristen_Sealey@golder.com | 

www.golder.com 

Work Safe, Home Safe 

This email transmission is confidential and may contain proprietary information for the exclusive use of the intended recipient. Any use, distribution or copying of 

this transmission, other than by the intended recipient, is strictly prohibited. If you are not the intended recipient, please notify the sender and delete all copies. 

Electronic media is susceptible to unauthorized modification, deterioration, and incompatibility. Accordingly, the electronic media version of any work product may 

not be relied upon. 

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation. 

Please consider the environment before printing this email. 

 

-- 

Andrea Stacy 

National Park Service 

Air Resources Division 

12795 W. Alameda Pkwy 

P.O. Box 25287 

Denver, CO 80225 

andrea_stacy@nps.gov

303-969-2816 (phone) 

303-969-2822 (Fax)