PSD-EPA-R4016; NHPC – Okeelanta Cogeneration Station_DRAFT_1-21-2014 1

***PUBLIC NOTICE COPY***

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region 4 

Atlanta, Georgia 

Prevention of Significant Deterioration Permit 

For Greenhouse Gas Emissions

Permit PSD-EPA-R4016

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

42 U.S.C. § 7470, the implementing Prevention of Significant Deterioration (PSD) of 

Air Quality Regulations at the Code of Federal Regulations (CFR) Title 40, Section 52.21 

(40 CFR § 52.21), and the Federal Implementation Plan (FIP) at 40 CFR § 52.37 [effective 

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

Protection Agency Region 4 hereby authorizes:

New Hope Power Company (NHPC)

Okeelanta Cogeneration Plant

8001 U.S. Highway 27 South

South Bay, Florida 33493

to construct and operate Greenhouse Gas (GHG) air emissions units as a modification to the 

existing Okeelanta Cogeneration Plant located at 8001 U.S. Highway 27 South, South Bay (Palm 

Beach County), Florida.

This modification to the Okeelanta Cogeneration Plant shall be constructed and operated in 

accordance with the terms and conditions set forth in this permit.

This permit becomes effective on [INSERT EFFECTIVE DATE].

This permit addresses GHG-related PSD requirements only. For this Project, the State of Florida, 

through the Florida Department of Environmental Protection (FDEP), retains jurisdiction over 

PSD permitting for regulated pollutants other than GHGs. This permit shall not relieve the owner 

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

law.

__________ ______________________

Date Signed Jeaneanne M. Gettle

Acting Director

Air, Pesticides, and Toxics

Management Division
PSD-EPA-R4016; NHPC – Okeelanta Cogeneration Station_DRAFT_1-21-2014 2

AUTHORITY

The EPA issues this permit pursuant to Subchapter I, Part C, of the Clean Air Act (CAA), 42 

U.S.C. § 7470, the implementing PSD Regulations at 40 CFR § 52.21, and the FIP at 

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

This permit is based upon application materials submitted to the EPA by New Hope Power

Company (NHPC), dated February 4, 2013; May 17, 2013; and November 11, 2013;

supplemental submittals in the administrative record for this permit action, and upon the 

technical analysis performed by the EPA.

APPLICANT

New Hope Power Company 

Okeelanta Cogeneration Plant

8001 U.S. Highway 27 South

South Bay, Florida 33493

PROJECT LOCATION

NHPC’s project will be located at the existing Okeelanta Cogeneration Plant located at 8001 

U.S. Highway 27 South, South Bay (Palm Beach County), Florida.

PROJECT DESCRIPTION

NHPC has applied for a Prevention of Significant Deterioration (PSD) air permit for the 

emission of Greenhouse Gases (GHGs) pursuant to the Clean Air Act (CAA) from the United 

States Environmental Protection Agency (EPA) Region 4 for a proposed project (Project) at the 

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

boiler (Boiler D) to be used primarily for steam at their existing 140-megawatt (MW) net electric 

cogeneration facility. 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). The primary fuel for Boiler D will be natural gas, with very low 

sulfur distillate fuel oil (fuel oil) used as backup. 

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

to limit emissions of GHGs to the greatest extent feasible.

EQUIPMENT LIST

The following devices and activities are subject to this PSD permit:
PSD-EPA-R4016; NHPC – Okeelanta Cogeneration Station_DRAFT_1-21-2014 3

Unit ID Description

Natural Gas 

Fired Boiler

 Maximum 1-hour combined heat input rate of 589 million British 

thermal units per hour (MMBtu/hr) (Higher Heating Value)

 Maximum 1-hour steam production rate of 440,000 lb/hr

 Use of economizer and air pre-heater

PERMIT CONDITIONS

I. PERMIT EXPIRATION

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

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

approval takes effect; or

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

C. is not completed within a reasonable time. 

II. PERMIT NOTIFICATION REQUIREMENTS

Pursuant to Condition IX: SPECIAL CONDITIONS, Permittee shall notify the EPA 

Region 4 of the:

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

B. actual date of initial setting in operation for any purpose, postmarked within 15 days 

of such date; and

C. date upon which initial certification tests will commence, in accordance with the 

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

Notification may be provided with the submittal of the certification test protocol

required pursuant to Condition IX.D.

III. FACILITY OPERATION

A. At all times, including periods of startup, shutdown, and malfunction, Permittee shall, 

to the extent practicable, maintain and operate the facility in a manner consistent with 

good air pollution control practice for minimizing emissions. Determination of 

whether acceptable operating and maintenance procedures are being used will be 

based on information available to the EPA, which may include, but is not limited to, 

monitoring results, review of operating maintenance procedures and inspection of the 

facility. 
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B. The Permittee shall operate and maintain the boiler and associated components in a 

manner consistent with good engineering practices for its full utilization.

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

40 CFR § 60.2) but prior to commencement of commercial operation, and thereafter, 

the Permittee shall develop and implement an operation and maintenance plan for the 

facility, consistent with Condition III.B above. At a minimum, the plan shall identify 

measures for assessing the performance of the facility, the acceptable range of the 

plant performance measures for achieving the design steam output, the methods for 

monitoring the plant performance measures, and the routine procedures for 

maintaining the facility in good operating condition.

IV. MALFUNCTION REPORTING

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

Condition X: AGENCY NOTIFICATIONS within two (2) calendar days following 

the discovery of any failure of process equipment, or failure of a process to operate in 

a normal manner, which results in an increase in emissions above the allowable 

emission limits stated in Condition IX of this permit.

B. In addition, pursuant to Condition X: AGENCY NOTIFICATIONS, Permittee shall 

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

failure described under Condition IV.A above. This notification shall include a 

description of the malfunctioning equipment or abnormal operation, the date of the 

initial malfunction, the period of time over which emissions were increased due to the 

failure, the cause of the failure, the estimated resultant emissions in excess of those 

allowed in Condition IX: SPECIAL CONDITIONS, and the methods utilized to 

mitigate emissions and restore normal operations. 

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

constitute a defense to any violation of this permit or any law or regulation such 

malfunction may cause.

V. RIGHT OF ENTRY

The EPA Regional Administrator, and/or an authorized representative, upon the 

presentation of credentials, shall be permitted:

A. to enter the premises where the facility is located or where any records are required to 

be kept under the terms and conditions of this PSD permit; 

B. during normal business hours, to have access to and to copy any records required to 

be kept under the terms and conditions of this PSD permit; 
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C. to inspect any equipment, operation, or method subject to requirements in this PSD 

permit; and

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

VI. TRANSFER OF OWNERSHIP

In the event of any changes in control or ownership of the facility, this PSD permit shall 

be binding on all subsequent owners and operators. Within 14 days of any such change in 

control or ownership, Permittee shall notify the succeeding owner and operator of the 

existence of this PSD permit and its conditions by letter. Permittee shall send a copy of 

this letter pursuant to Condition X: AGENCY NOTIFICATIONS to the EPA Region 4

within thirty (30) days of its issuance.

VII. SEVERABILITY

The provisions of this PSD permit are severable, and, if any provision of the PSD permit 

is held invalid, the remainder of this PSD permit shall not be affected.

VIII. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER 

ENVIRONMENTAL LAWS

A. Permittee shall construct the Project in compliance with this PSD permit, the 

application on which this permit is based, and all other applicable federal, state, and 

local air quality regulations. This PSD permit does not release the Permittee from any 

liability for compliance with other applicable federal, state and local environmental 

laws and regulations, including the Clean Air Act.

B. If prehistoric or historic artifacts, such as pottery or ceramics, stone tools or metal 

implements, or any other physical remains that could be associated with Native 

American cultures, or early colonial or America settlement are encountered at any 

time within the project site area, the permitted project should cease all activities 

involving subsurface disturbance in the immediate vicinity of such discoveries. Upon 

such discovery, Permittee, or other designee, shall contact the Florida Department of 

State, Division of Historical Resources, Review and Compliance Section at 

850.245.6333 or 800.847.7278, as well as the appropriate permitting agency office

(FDEP and the EPA Region 4). Project activities shall not resume without verbal 

and/or written authorization from the Division of Historical Resource. In the event 

that unmarked human remains are encountered during permitted activities, all work 

shall stop immediately and the proper authorities notified in accordance with Section 

872.05, Florida Statutes.
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IX. SPECIAL CONDITIONS

A. Air Pollution Control Equipment and Operation 

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

are at or below the emission limits specified in this permit. 

B. Boiler Emission and Operational Limits and Work Practices

1. For maximized efficiency, the Permittee shall maintain efficient burner design and 

optimization, capture of energy from boiler blowdown, insulate the unit, and utilize 

instrumentation/controls to achieve high-efficiency/low-emissions performance including 

but not limited to practices as described in the application.

2. At all times, Permittee shall not discharge, or cause the discharge of, emissions from the 

boiler into the atmosphere in excess of the following:

Operating Scenario GHG Emission Limit1

(on gross output basis) 

Natural Gas 157 pounds (lb) of carbon dioxide equivalent 

(CO2e) per 1,000 lbs steam produced 

(30-day rolling average)

Fuel Oil 218 lb CO2e per 1,000 lbs of steam produced

(3-hour rolling average)

1Compliance with the above limits shall be demonstrated in accordance with Condition IX.C.3.

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

63.7575), boiler shall be limited to operating no more than 48 hours per 12-month rolling 

period when burning fuel oil. Permittee shall monitor and record hours burning fuel oil 

monthly and totalled every month for the previous 12 months.

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

85% (thermal efficiency) in any month, on a 30-day rolling average.

C. Monitoring for Boiler

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

a. Heat input rate (MMBtu);

b. Steam output rate (1,000 lbs);

c. Unit operating time;
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d. The type of fuel and amount of fuel (natural gas or fuel oil) burned.

2. Permittee shall calculate and record, for the boiler:

a. On a daily basis, a 30 day rolling average CO2e emission rate, as described in 

Condition IX.C.3, (lbs CO2e /1,000 lbs Steam) calculated as the sum of each hourly 

CO2e emission rate times the unit operating time for the hour divided by the sum of 

the recorded steam output rates times the unit operating time for the hour for all hours 

of operation in each day averaged for the previous 30 days, while burning natural gas.

b. On an hourly basis, a 3-hour rolling average CO2e emission rate, as described in 

Condition IX.C.3, (lbs CO2e /1,000 lbs Steam) calculated as the sum of each hourly 

CO2e emission rate times the unit operating time for the hour divided by the sum of 

the recorded steam output rates times the unit operating time for the hour for all hours 

of operation in each hour averaged for the previous 3 hours, while burning fuel oil. 

c. On a daily basis, a 30 day rolling average conversion rate of heat input to steam 

produced, as described in Condition IX.B.4, calculated as the heat input rate times the 

unit operating time for the hour divided by the sum of the recorded useful steam

output rates times the unit operating time for the hour for all hours of operation in 

day, averaged for the previous 30 days.

3. For demonstrating compliance with the limits specified in Condition IX.B.2, Permittee 

shall use the procedures set forth in 40 CFR part 98 to determine resulting GHG 

emissions (as CO2e) based on the combination of calculated CO2 emissions and 

calculated CO2e of other GHG pollutants [as specified in Condition E: GLOBAL 

WARMING POTENTIAL (GWP)]. Permittee shall keep adequate records of these GHG 

emission calculations according to requirements in Condition IX.D.1, on a daily basis.

D. Recordkeeping and Reporting 

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

related to the operation of the facility, including, but not limited to, the following:

a. All records or reports pertaining to adjustments and/or maintenance performed on any 

system or device at the facility pertaining to GHG emissions;

b. All other information that this permit requires the Permittee to obtain, maintain, or 

develop, recorded in a permanent form suitable for inspection.

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

occurrence and duration of any startup, shutdown, malfunction, performance testing, 

evaluations, calibrations, checks, adjustments, maintenance, duration of any periods 

during which monitoring data is unavailable, and corresponding emission measurements.

3. Permittee shall maintain records of all source tests and monitoring and compliance 
PSD-EPA-R4016; NHPC – Okeelanta Cogeneration Station_DRAFT_1-21-2014 8

information required by this permit.

Permittee shall maintain records and submit a written report of all deviations from permit 

requirements to the EPA semi-annually, except when: more frequent reporting is 

specifically required by an applicable subpart; or the Administrator, on a case-by-case 

basis, determines that more frequent reporting is necessary to accurately assess the 

compliance status of the source. The report is due on September 30th and March 31st and 

shall include the following:

a. If applicable, time intervals, data and magnitude of the excess emissions, the nature 

and cause (if known), corrective actions taken and preventive measures adopted;

b. If applicable, the time and date of each period during which the monitoring data 

was unavailable (monitoring down-time), except for zero and span checks, and the 

nature of monitoring system repairs or adjustments;

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

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

repaired, or adjusted;

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

activities; and

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

on hours of operation.

5. Excess emissions shall be defined as any period in which the facility emissions exceed 

the maximum emission limits set forth in this permit.

6. A period of monitoring down-time shall be any unit operating clock hour in which 

sufficient data are not obtained by the monitoring methods to validate the hour for CO2e.

7. Excess emissions indicated by the monitoring, source testing, or compliance monitoring 

shall be considered violations of the applicable emission limit for the purpose of this 

permit.

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

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

years. Permittee shall also keep records of the monitoring data for each of the facility

performance measures and all maintenance activities; the Permittee shall maintain such 

records for a minimum of five years following the date they are created

9. Unless otherwise specified herein, all records required by this PSD permit shall be 

retained for not less than five (5) years following the date of such measurements, 

maintenance, reports, and/or records. These records shall be made available for review 
PSD-EPA-R4016; NHPC – Okeelanta Cogeneration Station_DRAFT_1-21-2014 9

upon request by the Agency or authorized representative during the course of an 

inspection.

E. Global Warming Potential (GWP)

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

GWP factors listed in 40 CFR part 98, subpart A, Table A-1 as of the date of this permit 

shall be used. The current GWP factors are listed below:

GHG Pollutant GWP Factor

CO2 1

CH4 25

N2O 298

X. AGENCY NOTIFICATIONS

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

submitted to:

Chief

Air & EPCRA Enforcement Branch

Air, Pesticides and Toxics Management Division

U.S. EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303

In addition, electronic copies of the above-referenced notifications and communications 

shall be submitted to the following individuals at their corresponding email address:

Name Email Phone

Jason Dressler dressler.jason@epa.gov 404-562-9208

Katy R. Lusky forney.kathleen@epa.gov 404-562-9130

Heather Ceron ceron.heather@epa.gov 404-562-9185