April 2012 1 113-87618

EPA4-PSD

Endangered Species Analysis

1EPA-T&E-1 In processing FPL's PSD permit application, the EPA must assure that listed species or their critical habitat will not be je opardized by the changes at the Port Everglades facility. However, endangered species have not b een discussed in FPL' s PSD permit application, other than a statement on page 5-10 of the application that FPL will comply with the Manatee Protection Plan for 3 years, and a statement on p age 5-11 that "No adverse impacts to federal or state listed species are expected in association with construction ... ". The information provided in the application is not detailed enough for us to de termine our obligations, if any, under Section 7 of

the ESA.

RESPONSE:

As discussed in Response 1EPA-T&E-2 below, info rmal Section 7 consultation has been initiated by EPA, and FPL will coordinate with NOAA and FWS to confirm the listed speci es to be assessed and action area for the Project. FPL will then prepar e a Biological Assessment containing Project-related

information from the Site Certification Application (SCA) . The Biological Assessment will provide the information necessary for EPA to determine its obliga tions regarding consultation under Section 7 of the

ESA.

1EPA-T&E-2 As part of the informal consultation process, FPL should provide a biological assessment to the EPA, FWS and NOAA Fi sheries. Please note that in order for the EPA to issue a final permit, we must ensure that the pr oposed action is not likely to jeopardize or the continued existence of any federally listed or endangered species or threatened species or result in

the destruction or adverse modification of such species' designated critical habitat.

RESPONSE:

EPA initiated informal consultation (under Section 7 of the ESA) with NOAA and FWS via letters submitted on February 22, 2012. In the same le tters, EPA has designated FPL as the non-federal representative responsible for preparing and submitting a Biological Assessment to assist EPA, FWS, and NOAA in making an effects determination on listed sp ecies and their critical habitat for the proposed Project. To date, only NOAA has responded to the EPA ’s request for informal consultation, and NOAA has requested a Biological Assessment to support an effects determination by EPA. FPL will coordinate with NOAA and FWS to confirm the listed species to be assessed and to define the action area for the Project. FPL will then prepare a Biological Assessment and make an effects determination for the species

within the action area. EPA can then coordina te with FWS and NOAA to obtain concurrence on the

effects determination.

Netting and BACT Analysis

1EPA-1 It is our understanding that two combustion turbine options (MHI "J" and Siemens "H") are being considered. On page 4-14 of the a pplication, a range of efficiency for natural gas firing (53.7% to 52.6%) or oil firing (50.6% to 47.6%) is presented, but it is unclear which efficiencies correspond technology (BACT) analysis that compares the energy efficiencies of each specific turbine being considered.April 2012 2 113-87618

EPA4-PSD

RESPONSE:

As discussed in Section 2.8 of the Air Construc tion Permit/PSD Application, the MPS “J” combustion turbines (CTs), and the Siemens “H” CTs were used to evaluate the air emissions and impacts of the Project. The CT vendor has not been selected and potential vendors will include MPS, Siemens, and General Electric. However, as discussed in the app lication, FPL desires to obtain guarantees of CT performance that will approximate the gross generati on of the MPS “J” CT in combined cycle operation while achieving emissions within the range of the em issions provided for the MPS “J” and Siemens “H”. This included performance and efficiency. Therefore, the MPS “J” is the basis of the Project for the purposes of the GHG BACT analysis. The efficiencies and heat rates provided in the discussion on page

4-14 were illustrative of the combustion turbines be ing considered. This demonstrated that the combustion turbines being considered are efficient compared to other available combustion turbines. Please also see Response 1EPA-2 below.

1EPA-2 On page 4-15 of the application, a Greenhouse Gas (GHG) BACT limit of 877 lb

CO 2 e/MW-hr on a 12-month rolling average is proposed as BACT for the combined cycle turbine. It appears that this limit is intended to cover both natural gas and fuel oil operation for either of the CT options being considered. However, the applic ation does not include detailed calculations to support this proposed limit. Please provide calc ulations to explain how this proposed limit was determined and include a breakdown of the exp ected use of oil versus natural gas operation. Furthermore, please clarify whether the proposed BACT limit is based on net or gross production of energy (MW-hr).

RESPONSE:

Table 1EPA-2-1 presents the basis for the proposed GHG BACT limit. The table presents the estimated performance and CO 2 e emissions for a combined cycle unit when firing natural gas and ultra low sulfur distillate (ULSD) oil. Please note that the basi s for the proposed GHG BACT limit presented in the application was on a net basis (inclusive of all in ternal losses of the 3-on-1 combined cycle unit). The operation for gas included a range of expected operati ng loads (100%, 75% and 50%) that may occur. As described in the application the an nual potential emissions are based on a turbine inlet temperature of

75 o F that is approximately the annual average temperat ure in Fort Lauderdale, Florida. The capacities and heat rates are based on net power generated that in cludes consideration of auxiliary loads. Operation on ULSD oil is the backup fuel and operation at 10 0% load is likely. The proposed GHG BACT limit was based on the maximum potential operation requ ested, which was 8,760 hours with up to 1,000 hours operation on oil.

On April 13, 2012, the EPA published in the Fede ral Register (72FR22392-22441), proposed Standards

of Performance for Greenhouse Gas Emissions for Ne w Stationary Sources: Electric Utility Generating Units (40 CFR Subpart TTTT). This proposed NSPS will be applicable to PEEC if finally approved. In this proposed NSPS, GHG emissi ons are limited to 1,000 lb CO 2 per gross output on a 12-month annual basis. As described above, the basis of the GHG em ission limit is on a net generation basis. Table 1EPA2-2 presents the proposed GHG BACT limit on a gross generation basis.

1EPA-3 The application does not indicate whet her or not there are sulfur hexafluoride (SF6) circuit breakers are used onsite. SF6 is associated with a significant C0 2 e global warming potential and can be released during the malfunction of th e circuit breakers. Please confirm whether SF6 circuit breakers are located at the facility. If they are, please provide an estimate of emissions and explain what leak detection and repair (LDAR) program will be used.April 2012 3 113-87618

EPA4-PSD

RESPONSE:

For the PEEC Project, there will be two circuit breakers containing SF 6 . Each breaker will be equipped with low density alarms and thoroughly leak tested with helium prior to delivery. Presented below is further information on GHG emissions from potential SF 6 fugitive emissions.

SF 6 BACT ANALYSIS

SF 6 is an electrical insulator and interrupter in equi pment that transmits and distributes electricity. SF 6 has been broadly used in the U.S. due to its diel ectric strength and arc-quenching characteristics and has replaced flammable insulting oils.

Circuit breakers associated with the PEEC Project are estimated to contain approximately 75 lbs of SF 6

. Based on the guaranteed leak rate, not to exceed 0. 5 percent/year, the estimated GHG emissions from the

circuit breakers are as follows:

 75 lb SF 6 x 0.005 leakage/year = 0.375 lb SF 6 /year

 0.375 lb SF 6 /year x 23,900 CO2e/lb SF 6 (Table A-1, 40 CFR Part 98) = 8,962.5 lb CO 2 e

The following presents additional info rmation related to BACT for the ci rcuit breakers to be installed as part of the PEEC Project.

EPA has recommended since 1990 that permitting authoriti es use the five step “top down” BACT process to determine BACT. The top down process calls for all available control technologies for a given pollutant to be identified and ranked in descending orde r of control effectiveness. The permit applicant should first examine the highest ranked (“top”) option. The top ranked options should be established as BACT unless the permit applicant demonstrates to the satisfaction of the permitting authority that technical considerations, or energy, environmental, or economic impacts justify a conclusion that the top ranked technology is not “achievable” in that case. If the most effective control strategy is eliminated in this fashion, then the next most effective alterna tive should be evaluated, and so on, until an option is

selected as BACT.

EPA has broken down this “top down” pr ocess into the following five steps:

Step 1: Identify all available control technologies

Step 2: Eliminate technically infeasible options

Step 3: Rank remaining control technologies

Step 4: Evaluate most effective controls and document results

Step 5: Select the BACTApril 2012 4 113-87618

EPA4-PSD

Step 1

– Identify All Available Control Technologies

The first step in the top down BA CT process is to identify all “ava ilable” control options. Available control options are those air pollution control te chnologies or techniques (including lower emitting processes and practices) that have the potential for practical application to the emissions unit and the regulated pollutant under evaluation.

The available control options include alternative (non-SF 6 ) dielectric fluids and minimizing the fugitive

emission of SF 6 . Historically dielectric fluids such as diel ectric oils have been used in high voltage applications. However, the use of these materials in circuit breakers has been predominately replaced

with SF 6 that has excellent dielectric and arc quenc hing properties and is not flammable.

Modern SF 6 circuit breakers are designed as totally encl osed-pressure systems with low potential SF 6 fugitive emissions. Leakage is typically guaranteed to be no more than 0.5 percent by weight. It should be recognized that actual leakage rate are lik ely 0.1 percent by weight based on EPA SF 6 Emission Reduction Partnership. In addition, circuit breakers have density alarms that provide warnings if a leak is occurring. Density alarms provide notification if a le ak has occurred and corrective action is necessary. In addition, this equipment is routinely inspected to insure proper operation since this equipment is necessary for the safe operation of PEEC.

Step 2

– Identification of Technically Feasible Control Alternatives

Under the second step of the top down BACT analysis, a potentially applicable control technique listed in Step 1 may be eliminated from further consideration if it is not technically feasible for the specific source under review. EPA considers a technology to be poten tially applicable if it has been demonstrated in practice or is available.

Circuit breakers using SF 6 with alarms and periodic inspection are technically feasible for the PEEC Project. The use of alternative dielectric fluids is not practicable for high voltage applications. Circuit breakers using SF 6 are presently superior in their performance to alternative systems such as dielectric oil, high pressure air blast or vacuum circuit breakers. Moreover, EPA SF 6 Partnership has recognized that there is no clear alternative to using SF 6 and fugitive emissions are redu ced by implementing detection, repair and replacement strategies [EPA, 2011; (SF 6 Emission Reduction Partnership for Electric Power Systems, 2010 Annual Report, December 2011)].

Step 3

– Rank Remaining Control Technologies

After the list of all available controls is narrowed down to a list of the technically feasible control technologies in Step 2 above, Step 3 of the top do wn BACT process calls for the remaining control technologies to be listed in order of overall contro l effectiveness for the regulated NSR pollutant under review. The most effective control alternative (i.e., the option that achieves the lowest emissions level) should be listed at the top and the remaining technologies ranked in descending order of control

effectiveness.

The most effective control of fugitive SF 6 emissions is using totally enclosed system equipped with leak detection and periodic inspection a nd maintenance. The expected guarantee meets the requirements of the International Electrotechnical Commission (IEC) standard of 0.5 percent (IEC Standard 62271-1, 2004) that is recognized by the EPA SF 6 Reduction Partnership as an effective criterion for minimizing fugitive SF 6 emissions.April 2012 5 113-87618

EPA4-PSD

Step 4

– Economic, Energy, and Environmental Impacts

Under Step 4 of the top down BACT analysis, econom ic, energy, and environmental impacts must be evaluated for each option remaining under consideration.

The “top” control option and in the case of GHG the “top” energy reduction technology should be established as BACT unless the applicant demonstrat es, and the permitting authority agrees, that the energy, environmental, or economic impacts justify a conclusion that the most stringent technology is not “achievable” in that case. If the most stringent technolog y is eliminated in this fashion, then the next most stringent alternative is considered, and so on.

The “top” control option is the use of SF 6 circuit breakers that offer low economic, energy and environmental impacts. SF 6 is the preferred gas for electrical insulation, arch quenching and current insulation for high voltage equipment. It is chemic ally inert, non-toxic, non-flammable, non-explosive and thermally stable. SF 6 exhibits properties that are beneficial from an economic, energy and environmental standpoint when used in totally enclosed systems.

Step 5

– Select the BACT

In Step 5 of the BACT determination process, the most effective control option not eliminated in Step 4 should be selected as BACT for the pollutant and emi ssions unit under review and included in the permit.

BACT

Based on the top-down analysis, the only technically feasible controls technologies for the SF 6 circuit breakers associated with the PEEC project are the use of modern totally enclosed with a guarantee leakage rate of 0.5 percent that are thoroughly test ed, equipped with leak detection systems (density alarms) and performing periodic inspection. Together these controls will minimize SF 6 fugitive emissions

to no more than 4.5 tons CO 2 e/year.

1EPA-4 BACT applies at all times. The p ermit application includes a proposed BACT

emission limit of 877 lb C0 2 e/MW-hr on a 12-month rolling average. Please clarify whether this emission limit incorporates startup/shutdown emissions, or whether an alternative BACT limit will apply during periods of startup/shutdown. We note that Table A-17 and Table B-17 show the estimated greenhouse gas (GHG) emissions for the MPS 501J and the SIEMENS H, respectively, but do not indicate if startup/shutdown emission s were included in the calculations. Please also explain the anticipated time in startup/shutdown mode for each of the combined cycle units being

considered.

RESPONSE:

The proposed BACT limit of 877 lb CO 2 e/MW-hr on a 12-month rolling average included consideration of startup/shutdown. As shown in Tables 1EAP-2-1 and 1EAP-2-2, the CO 2 e/MW-hr emission rate considered a range of operating loads that would accommodate lower loads experienced during startup/shutdown conditions.

1EPA-5 Section 4.3.2 includes the BACT analys is for the auxiliary boiler and other units that will operate for a limited amount of time. Step 1 of the BACT analysis for the auxiliary boiler, page 4-19, references the EPA's PSD and Titl e V Permitting Guidance for GHGs. Please alsoApril 2012 6 113-87618

EPA4-PSD

consider the EPA's "Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from Industrial, Commer cial, and Institutional Boilers" http://www.e.pa.gov/nsr/ghgdocs/iciboilers.pdf. This document contains additional energy efficient improvements that are not considered in the analysis provided in Section 4.3.2, such as air preheat economizers, operation and maintenance practices, boiler insulation, and others. The applicant should either explain why these measures were not included in the BACT analysis, or provide a revised BACT analysis that includes any additional applicable control technologies.

RESPONSE:

Presented herein is additional information of effi ciency improvement measures described in EPA’s “Available and Emerging Technologies for Reduci ng Greenhouse Gas Emissions from Industrial, Commercial, and Institutional Boilers ” document, which are applicable to the proposed new natural gasfired auxiliary boiler of the PEEC.

As mentioned in the original energy efficiency discussion (Page 4-19, Section 4.3.2), a commercial or residential boiler's efficiency is measured by its annu al fuel utilization efficiency (AFUE). The AFUE of natural gas-fired residential boilers is in the 90% range. The efficien cy of industrial boilers, which are usually “custom-made” and not “off-the-shelf”, are b ased on the use of the boiler in the industry and the specification followed in its design. Usually there is a specific steam pressure, temperature requirement,

and emission threshold that the boiler must meet. As a result, two equal size boilers at two different industries may have different design efficiencies. According to the “Boiler Efficiency Projects” document prepared for California Climate Actions Regi stry in 2009, industrial natural gas-fired boilers producing steam have high heating va lue thermal efficiencies of 75% - 83%. While the auxiliary boiler for PEEC has not yet been purchased, it is expected th at the design will be similar to the Babcock and Wilcox auxiliary boiler at FPL’s West County Energy Center (WCEC). WCEC consists of three 1,250 MW new combined cycle units similar to PEEC. As a result, the design efficiency of the proposed auxiliary boiler at PEEC is expected to be 84% to 82% from loads of 100% to 25%. The majority of the

thermal losses are due to the water formed in comb ustion (about 10.5%) while radiation losses range from 0.55% to 2.3%. The remaining losses are dry gas, mo isture in the air and miscellaneous. Since this auxiliary boiler is designed for a specific purpose during the startup of the PEEC combined cycle unit, it is designed for maximum efficiency.

Several energy efficiency improvement measures are di scussed below and evaluated for their applicability to the PEEC Project’s auxiliary boiler.

Operating and Maintenance (O&M) Practices – The auxiliary boiler at PEEC will be brand new and specifically designed for its intended use for PEEC. A lthough some deterioration in the design efficiency of the boiler is expected to occur over time, based on the history of maintenance and operation at all FPL power plants, the deterioration is expected to be mi nimal. Equipment deterioration primarily occurs over time with continued use. The auxiliary boiler is used for startup with limitations on its use as described in the PEEC Air Construction/PSD Permit Application. In addition, the auxiliary boiler is used to only supply sufficient steam for startup and has extended peri ods where it is not being used while any of the 3 CT/HRSG trains of the 3-on-1 combined cycle unit is operating. This allows sufficient time to ensure proper maintenance is performed.

New Burners/Upgrades – This auxiliary boiler to support startup of the combined cycle unit will be a new unit and designed with new efficient burners. Th e maintenance plan will address the maintenance of the boiler including burners a nd replacements as necessary to support efficient operation.April 2012 7 113-87618

EPA4-PSD

Improved Combustion Measures – Tuning of the combustion system improves combustion efficiency of the older, mechanically deteriorated boilers, which may have deteriorated from the manufacturer’s recommendations or the optimum settings developed fo r the particular boiler. The new boiler at PEEC will be designed specifically for its intended use with overall efficiency of 84% to 82%. The new boiler

will be installed and tuned to meet the effici encies and operated according to the manufacturer’s recommendations. These modern boilers will be equi pped with digital instrumentation and control systems that will continuously monitor and optimize performance.

Air Preheat and Economizers – For most fossil fuel-fired heating equipment, energy efficiency can be increased by using waste heat gas recovery systems to cap ture and use some of the heat in the flue gas. The auxiliary boiler will have an economizer to ma ximize efficiency. Based on a similar design as the auxiliary boiler for WCEC, the temper ature at the entrance of the econom izer is over 600°F while the exit temperature is less than 300°F. However, air preheaters are typically used in much larger boilers such as the ones used in electric utility industry with heat in puts in excess of 1,000 MMBtu/hr and an order of magnitude larger than the auxiliary boiler. The pr oposed 99.9 MMBtu/hr limited use auxiliary boiler has a design efficiency of more than 80% and will be used for startup only, as needed. Installation of an air preheater is not practical for the auxiliary boiler. An air preheater would also impose additional pressure loss on the system.

Boiler Insulation – Significant heat loss can occur through the boiler shell, especially for large boilers

such as the ones used in the electri c utility industry. The proposed ne w auxiliary boiler will be properly insulated by the manufacturer to keep the heat en ergy losses to a minimum. As described above, the

radiation losses are 0.55% at full load and 2.3% at 25 % load. This demonstrates that radiation losses will

be minimal.

Boiler Blowdown Heat Exchanger – Blowdown is required to maintain water quality. However, some energy is lost. This waste heat can be recovered wi th a heat exchanger, flash tank, etc. to improve the overall efficiency of the boiler. Based on EPA’s Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from Industrial, Commercial , and Institutional Boilers document, any boiler with continuous blowdown exceeding 5% of the steam rate is a good candidate for considering blowdown waste heat recovery. The PEEC Project’s auxiliary boiler is expected to have a design continuous blowdown of only 2%.

As discussed above, energy efficiency improvement measures are not applicable to the proposed new auxiliary boiler, which will have a d esign efficiency of more than 80%.

1EPA-6 Section 4.3.2 Step 1 of the BACT analysis on page 4-19 evaluates the natural gas heater, the natural gas compressor, the emergenc y generators, and the diesel fire pump engine, but does not indicate the thermal efficiency of the indi vidual units or compare the efficiency of the units to other commercially available uni ts. Please revise the BACT analysis to confirm that these are the most energy efficient units, or explain why a unit wi th higher relative efficiency was not chosen as

BACT.

RESPONSE:

The proposed natural gas-fired fuel h eater will be used to preheat natu ral gas to keep the gas above the dew point temperature. The heater will be an indi rect-fired type where the firetube is surrounded by a chamber full of natural gas and heat transfer will o ccur between the fire tube and the thermal reservoirApril 2012 8 113-87618

EPA4-PSD

that transfers heat to the natural gas. While the auxiliary boiler for PEEC has not yet been purchased, it is expected that the design will be si milar to the fuel heater for WCEC. As a result, the proposed PEEC heater will have an efficiency of 62% (amount of h eat transferred/amount of heat input into heater). Please note that the proposed fuel heater is similar to a commercial boiler used for hot water or space heating and cannot be compared to commercial boilers. The fuel heater is expect ed to use indirect heat transfer where a heat transfer fluid (e.g., water a nd ethylene glycol mixture) maintains the required temperature of the natural gas. The proposed gas-fire d fuel heater is standard equipment used in power plants to preheat natural gas and such equipment is used successfully in hundre ds of utility, processing, and upstream oil and gas industry applications.

The proposed natural gas compressor is a mechanical device that will increase the pressure of the natural gas fuel. While the compressor itself is not a source of GHGs, the compressor requires a prime mover to supply the necessary mechanical energy. A Solar Cent aur 50 gas turbine has been selected to provide the mechanical energy for the compresso r. While the energy efficiency of the turbine is 29.3% (based on the Caterpillar data sheet on the Solar Centaur 50 turbine) the primary criteria is the power required for the compression. For the PEEC Project, approximately 5, 500 hp is required to s upply natural gas at the intended amount and pressure. The Solar Centaur 50 tu rbines match this requirement. In addition, the air emission profile for the Solar 50 turbine is much less th an natural gas-fired diesel engines. There are no natural gas-fired diesel engines meeting the compression requirements of the CTs.

The fire-pump engine is a 300-hp compression-igniti on diesel-fired internal combustion engine with a design fuel flow of 16.9 gal/hr and a heat input of 2.32 MMBtu/hr (Table 2-7 in the PEEC Air Construction/PSD Permit App lication). The maximum CO 2 e emissions are less than 20 tons CO 2 e/year at the requested hours of operation (100 hours). The gr oss output and thermal efficiency can be calculated

as follows:

 Gross Mechanical Output = Horsepower Rating (300 hp) 

### × Thermal Output Conversion Factor (2,546.4 Btu/hr/hp) = 763,920 Btu/hr

 Thermal Efficiency of Engine = Gross Mech anical Output (763,920 Btu/hr)/Heat Input (2,320,000 Btu/hr) x 100 = 32.9%

Based on information from similar FPL projects, the fi re pump engine will be turbocharged and air-tocoolant aftercooled for increased efficiency. As stated in the application, the fire pump engine is for emergency service and typically operates only a few hour s per year for maintenance. In addition, as required by Subpart IIII, the fire pump engine w ill be operated and maintained according to the

manufacturer's emission-related written instructions that are necessary to maintain emissions and efficiency.

The emergency generators are 3,200- hp, 2,250 kW diesel-fired emergenc y generators. Each generator has a fuel use of 152.6 gal/hr of design fuel flow and thermal heat input of 21 MMBtu/hr (Table 2-5 in the PEEC Air Construction/PSD Permit Application). The maximum CO 2 e emissions are 343.6 tons

CO 2 e/year at the requested hours of operation (100 hour s). The gross output and thermal efficiency and electrical efficiency can be calculated as follows:April 2012 9 113-87618

EPA4-PSD

 Gross Mechanical Output = Horsepower Rating (3,200 hp) 

### × Thermal Output (2,546.4 Btu/hr/hp)
= 8,148,480 Btu/hr

 Thermal Efficiency of Engine = Gross Mechanical Output (8 ,148,480 Btu/hr)/Heat Input (21,010,000 Btu/hr) x 100 = 38.8%

 Heat Rate = Heat Input (21,010,000 Btu/hr)/Electrical Output (2,250 kW) = 9,338 Btu/kW-hr

 Efficiency = Thermal-Electrical Conversion Factor (3,413 Btu/kW-hr)/Heat Rate (9,338 Btu/kWhr = 36.6%

Based on information from similar FPL projects, the em ergency generators will be turbocharged and airto-coolant aftercooled for increased efficiency. In add ition, the efficiency of the electrical generator is 94% (36.6%/38.8%). As stated in the application, the emergency generators are for emergency service and typically operated only a few hours per year for ma intenance. Moreover, as required by Subpart IIII the fire pump engine will be operated and maintain ed according to the manuf acturer's emission-related written instructions that are necessary to maintain emissions and efficiency.

1EPA-7 The BACT analysis for the emergency generator and the fire pumps, both proposing to burn fuel oil, assumes that compliance with applicable NSPS and NESHAP requirements will assure maximum efficiency. While these units must comply with these national standards, these requirements are a minimum threshol d and not an evaluation of efficiency or available technologies as required under BACT. Furth ermore, it does not appear that the use of natural gas was considered as part of the BACT an alysis for these units. Since natural gas will be used elsewhere at the facility, and may be a more ener gy efficient fuel than fuel oil, it is reasonable to consider natural gas in the BACT analysis for each of these units. The analysis should conclusively show that FPL will use the best a vailable control technology after considering all available technologies or inherently lower-emitting processes, practices or designs (or combinations thereof), including the use of natural gas or an explanation why such use was not considered.

RESPONSE:

Please see Response 1EPA-6 above for further inform ation on the emergency ge nerators and fire pump engines. The emergency generators and fire pump engi nes require a firm fuel supply in the event of any emergency including hurricanes where the natural gas supply can, and has historically, been disrupted. The use of ULSD oil achieves this purpose as ULSD fuel will be available on the PEEC site. In addition, as described in the PEEC Air Construction/PSD Applica tion, these units will normally be operated 1 to 2 hours per month for maintenance checks and resu lt in minimal GHG emissions. For the fire pump engine, the use of natural gas for maintenance tes ting instead of ULSD oil would reduce GHG emissions by only 1.35 tons CO 2 e. For the emergency generators, natura l gas for maintenance testing instead of

ULSD oil would reduce GHG emi ssions by only 21.44 tons CO 2 e.

The optional use of natural gas fundamentally changes the design of the source (engines) since the use of natural gas in a diesel engine requires special modifica tions (not off the shelf) and storage of natural gas for emergency use. The storage of natural gas requi res considerable special infrastructure. Dual fuel diesel engines also require the use of dist illate oil for ignition (a few percent).

The use of efficient ULSD oil-fired diesel emergenc y engines is available and demonstrated technology for these purposes and is considered BACT for the PEEC Project.April 2012 10 113-87618

EPA4-PSD

1EPA-8 According to page 2-11 of the PSD app lication, the proposed project will include the installation and use of a natural gas-fired "con struction boiler" which will be used up to 1500 hours/year during the construction period for the repowering project. While this phase of the project will not result in worst case emissions and therefore not affect the applicability analysis of this project, these emissions are subject to the requirements of PSD permitting. Please provide GHG BACT analysis which follows the top-down BACT process for the GHG emissions from the

construction boiler.

RESPONSE:

The BACT analysis presented in Section 4.3.2 for th e auxiliary boiler would apply to the construction boilers and the same BACT measures also apply to the construction boilers. The energy efficiency improvement measures discussed in Response 1EPA-6 above are applicable to the construction boilers. They will be used up to 1500 hours/year only during the construction period. Th e construction boilers are expected to have efficiencies of greater than 80%. In addition, while these boilers are not designed for a specific purpose like the PEEC auxiliary, their use is limited to supplying only the steam for cleaning piping. Steam pipe cleaning must follow very specific procedures established by the contractor to clean the piping prior to connections and startup. As a result, the boilers are not fired at maximum capacity unless required. Moreover, these cons truction boilers will not be on the PEEC Site for longer than 12 months and not in service during the operation of all other sources (e.g. combined cycle unit).

The auxiliary boiler, natural gas heater, emergency generator, fire pump e ngine, and the natural gas compressor described in Section 4.3.2 of the PSD Report use natural gas fuel and have very limited annual operating hours as the BACT for GHG emissions from the construction boilers. Compared to the proposed new CTs at PEEC, the construction boilers are minor GHG emission sources with minimal GHG emissions potential.

1EPA-9 Please verify that there have been no other creditable emission increases or decreases during the contemporaneous period as defined in 52.21 (b)(3)(ii) beyond the planned shutdown of existing boiler units 1-4.

RESPONSE:

FPL confirms that there are no other creditable emission increases or decreases during the contemporaneous period as defined in 40 CFR 52.21( b)(3)(ii) beyond the permanent shutdown of Port Everglades Units 1 through 4.Table 1EPA-2-1. MPS "J" Estimated Performance and Proposed GHG BACT Limit (Net Basis)Category UnitsFuel Gas Gas Gas ULSD OilTurbine Inlet degree F 75 75 75 75Evaporative Cooler On Off Off OnLoad % 100% 75% 50% 100%CT Units Operating 3 3 3 3Heat Input MMBtu/hr (HHV) 8,416.53 6,685.72 5,106.26 7,171.06CO2e lb/hr 984,992 782,434 597,588 1,173,407Net Output kW 1,330,432 1,017,017 731,608 1,006,652Net Heat Rate Btu/kWh (HHV) 6,325 6,572 6,978 7,122CO2e lb CO2e/MWh 740 769 817 1,166Gas Average CO2e lb CO2e/MWh 776 (Average of 100%, 75% and 50% load)Gas Operation hours 7,760 (Max gas operation with max oil)Oil CO2e lb CO2e/MWh 1,166 (Oil GHG emissions)Oil Operation hours 1,000 (Max potential oil operation)Average Gas/Oil CO2e lb CO2e/MWh 820 (Gas x 7,760 + Oil x 1,000)/8,760Margin for Guarantee % 2% (No guarantee from vendor)Margin for Degradation % 5% (Account for normal wear)Proposed CO2e lb CO2e/Mwha877 7% higher than estimated gas/oila12-month rolling averageEstimated PerformanceTable 1EPA-2-2. MPS "J" Estimated Performance and Proposed GHG BACT Limit (Gross Basis)Category UnitsFuel Gas Gas Gas ULSD OilTurbine Inlet degree F 75 75 75 75Evaporative Cooler On Off Off OnLoad % 100% 75% 50% 100%CT Units Operating 3 3 3 3Heat Input MMBtu/hr (HHV) 8,416.53 6,685.72 5,106.26 7,171.06CO2e lb/hr 984,992 782,434 597,588 1,173,407Gross Output kW 1,372,005 1,052,444 761,474 1,044,071Gross Heat Rate Btu/kWh (HHV) 6,134 6,353 6,706 6,868CO2e lb CO2e/MWh 718 743 785 1,124Gas Average CO2e lb CO2e/MWh 749 (Average of 100%, 75% and 50% load)Gas Operation hours 7,760 (Max gas operation with max oil)Oil CO2e lb CO2e/MWh 1,124 (Oil GHG emissions)Oil Operation hours 1,000 (Max potential oil operation)Average Gas/Oil CO2e lb CO2e/MWh 792 (Gas x 7,760 + Oil x 1,000)/8,760Margin for Guarantee % 2% (No guarantee from vendor)Margin for Degradation % 5% (Account for normal wear)Proposed CO2e lb CO2e/Mwha847 7% higher than estimated gas/oila12-month rolling averageEstimated Performance