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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 jeopardized by the changes at the Port Everglades 

facility. However, endangered species have not been 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 page 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 determine our obligations, if any, under Section 7 of 

the ESA. 

RESPONSE: 

As discussed in Response 1EPA-T&E-2 below, informal Section 7 consultation has been initiated by 

EPA, and FPL will coordinate with NOAA and FWS to confirm the listed species to be assessed and 

action area for the Project. FPL will then prepare 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 obligations 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 Fisheries. Please note that in order for the EPA 

to issue a final permit, we must ensure that the proposed 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 letters, 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 species 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 coordinate 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 application, 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. 
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RESPONSE: 

As discussed in Section 2.8 of the Air Construction 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 application, FPL desires to obtain guarantees of CT 

performance that will approximate the gross generation of the MPS “J” CT in combined cycle operation 

while achieving emissions within the range of the emissions 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 being 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 

CO2 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 application does not include detailed calculations to 

support this proposed limit. Please provide calculations to explain how this proposed limit was 

determined and include a breakdown of the expected 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 CO2e emissions for a combined cycle unit when firing natural gas and ultra low sulfur 

distillate (ULSD) oil. Please note that the basis for the proposed GHG BACT limit presented in the 

application was on a net basis (inclusive of all internal losses of the 3-on-1 combined cycle unit). The 

operation for gas included a range of expected operating loads (100%, 75% and 50%) that may occur. As 

described in the application the annual potential emissions are based on a turbine inlet temperature of 

75o

F that is approximately the annual average temperature in Fort Lauderdale, Florida. The capacities 

and heat rates are based on net power generated that includes consideration of auxiliary loads. Operation 

on ULSD oil is the backup fuel and operation at 100% load is likely. The proposed GHG BACT limit 

was based on the maximum potential operation requested, which was 8,760 hours with up to 1,000 hours 

operation on oil. 

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

of Performance for Greenhouse Gas Emissions for New 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 emissions are limited to 1,000 lb CO2 per gross output on a 12-month annual 

basis. As described above, the basis of the GHG emission 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 whether or not there are sulfur hexafluoride (SF6) 

circuit breakers are used onsite. SF6 is associated with a significant C02e global warming potential 

and can be released during the malfunction of the 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. 
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RESPONSE: 

For the PEEC Project, there will be two circuit breakers containing SF6. 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 SF6 fugitive emissions. 

SF6 BACT ANALYSIS

SF6 is an electrical insulator and interrupter in equipment that transmits and distributes electricity. SF6

has been broadly used in the U.S. due to its dielectric 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 SF6. 

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 SF6 x 0.005 leakage/year = 0.375 lb SF6/year 

 0.375 lb SF6/year x 23,900 CO2e/lb SF6 (Table A-1, 40 CFR Part 98) = 8,962.5 lb CO2e 

The following presents additional information related to BACT for the circuit breakers to be installed as 

part of the PEEC Project. 

EPA has recommended since 1990 that permitting authorities 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 order 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 alternative should be evaluated, and so on, until an option is 

selected as BACT. 

EPA has broken down this “top down” process 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 BACT 
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Step 1 – Identify All Available Control Technologies

The first step in the top down BACT process is to identify all “available” control options. Available 

control options are those air pollution control technologies 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-SF6) dielectric fluids and minimizing the fugitive 

emission of SF6. Historically dielectric fluids such as dielectric oils have been used in high voltage 

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

with SF6 that has excellent dielectric and arc quenching properties and is not flammable. 

Modern SF6 circuit breakers are designed as totally enclosed-pressure systems with low potential SF6

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 likely 0.1 percent by weight based on EPA SF6 Emission 

Reduction Partnership. In addition, circuit breakers have density alarms that provide warnings if a leak is 

occurring. Density alarms provide notification if a leak 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 potentially applicable if it has been demonstrated in 

practice or is available. 

Circuit breakers using SF6 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 SF6 are presently superior in their performance to alternative systems such as dielectric oil, 

high pressure air blast or vacuum circuit breakers. Moreover, EPA SF6 Partnership has recognized that 

there is no clear alternative to using SF6 and fugitive emissions are reduced by implementing detection, 

repair and replacement strategies [EPA, 2011; (SF6 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 down BACT process calls for the remaining control 

technologies to be listed in order of overall control 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 SF6 emissions is using totally enclosed system equipped with leak 

detection and periodic inspection and 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 SF6 Reduction Partnership as an effective criterion for minimizing 

fugitive SF6 emissions. 
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Step 4 – Economic, Energy, and Environmental Impacts

Under Step 4 of the top down BACT analysis, economic, 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 demonstrates, 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 technology is eliminated in this fashion, then the next 

most stringent alternative is considered, and so on. 

The “top” control option is the use of SF6 circuit breakers that offer low economic, energy and 

environmental impacts. SF6 is the preferred gas for electrical insulation, arch quenching and current 

insulation for high voltage equipment. It is chemically inert, non-toxic, non-flammable, non-explosive 

and thermally stable. SF6 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 emissions unit under review and included in the permit. 

BACT

Based on the top-down analysis, the only technically feasible controls technologies for the SF6 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 tested, equipped with leak detection systems (density 

alarms) and performing periodic inspection. Together these controls will minimize SF6 fugitive emissions 

to no more than 4.5 tons CO2e/year. 

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

emission limit of 877 lb C02e/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 emissions 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 CO2e/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 CO2e/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 analysis 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 Title V Permitting Guidance for GHGs. Please also 
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consider the EPA's "Available and Emerging Technologies for Reducing Greenhouse Gas 

Emissions from Industrial, Commercial, 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 efficiency improvement measures described in EPA’s 

“Available and Emerging Technologies for Reducing 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 annual fuel utilization efficiency (AFUE). The AFUE of 

natural gas-fired residential boilers is in the 90% range. The efficiency of industrial boilers, which are 

usually “custom-made” and not “off-the-shelf”, are based 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 Registry in 2009, industrial natural gas-fired boilers 

producing steam have high heating value thermal efficiencies of 75% - 83%. While the auxiliary boiler 

for PEEC has not yet been purchased, it is expected that 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 combustion (about 10.5%) while radiation losses range from 

0.55% to 2.3%. The remaining losses are dry gas, moisture 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 discussed 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. Although 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 minimal. 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 periods 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. The maintenance plan will address the maintenance of 

the boiler including burners and replacements as necessary to support efficient operation. 
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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 for 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 efficiencies and operated according to the manufacturer’s 

recommendations. These modern boilers will be equipped 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 capture and use some of the heat in the flue gas. 

The auxiliary boiler will have an economizer to maximize efficiency. Based on a similar design as the 

auxiliary boiler for WCEC, the temperature at the entrance of the economizer 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 inputs in excess of 1,000 MMBtu/hr and an order of 

magnitude larger than the auxiliary boiler. The proposed 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 electric utility industry. The proposed new auxiliary boiler will be properly 

insulated by the manufacturer to keep the heat energy 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 with 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 design 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 emergency generators, and the diesel fire pump engine, but 

does not indicate the thermal efficiency of the individual units or compare the efficiency of the units 

to other commercially available units. Please revise the BACT analysis to confirm that these are the 

most energy efficient units, or explain why a unit with higher relative efficiency was not chosen as 

BACT. 

RESPONSE: 

The proposed natural gas-fired fuel heater will be used to preheat natural gas to keep the gas above the 

dew point temperature. The heater will be an indirect-fired type where the firetube is surrounded by a 

chamber full of natural gas and heat transfer will occur between the fire tube and the thermal reservoir 
April 2012 8 113-87618 

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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 similar to the fuel heater for WCEC. As a result, the proposed PEEC 

heater will have an efficiency of 62% (amount of heat 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 expected to use indirect heat 

transfer where a heat transfer fluid (e.g., water and ethylene glycol mixture) maintains the required 

temperature of the natural gas. The proposed gas-fired fuel heater is standard equipment used in power 

plants to preheat natural gas and such equipment is used successfully in hundreds 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 Centaur 50 gas turbine has been selected to provide the 

mechanical energy for the compressor. 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 supply natural gas at the 

intended amount and pressure. The Solar Centaur 50 turbines match this requirement. In addition, the air 

emission profile for the Solar 50 turbine is much less than 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-ignition 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 Application). The maximum CO2e emissions are less than 20 tons CO2e/year at 

the requested hours of operation (100 hours). The gross 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 Mechanical Output (763,920 Btu/hr)/Heat Input 

(2,320,000 Btu/hr) x 100 = 32.9% 

Based on information from similar FPL projects, the fire 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 hours per year for maintenance. In addition, as 

required by Subpart IIII, the fire pump engine will 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 emergency 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 CO2e emissions are 343.6 tons 

CO2e/year at the requested hours of operation (100 hours). The gross output and thermal efficiency and 

electrical efficiency can be calculated as follows: 
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 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 emergency generators will be turbocharged and airto-coolant aftercooled for increased efficiency. In addition, 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 maintenance. Moreover, as required by Subpart IIII 

the fire pump engine will be operated and maintained according to the manufacturer'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 threshold and not an evaluation of efficiency or 

available technologies as required under BACT. Furthermore, it does not appear that the use of 

natural gas was considered as part of the BACT analysis for these units. Since natural gas will be 

used elsewhere at the facility, and may be a more energy 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 available 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 information on the emergency generators and fire pump 

engines. The emergency generators and fire pump engines 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 Application, these units will normally be operated 1 to 2 

hours per month for maintenance checks and result in minimal GHG emissions. For the fire pump 

engine, the use of natural gas for maintenance testing instead of ULSD oil would reduce GHG emissions 

by only 1.35 tons CO2e. For the emergency generators, natural gas for maintenance testing instead of 

ULSD oil would reduce GHG emissions by only 21.44 tons CO2e. 

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 modifications (not off the shelf) and storage of natural gas 

for emergency use. The storage of natural gas requires considerable special infrastructure. Dual fuel 

diesel engines also require the use of distillate oil for ignition (a few percent). 

The use of efficient ULSD oil-fired diesel emergency engines is available and demonstrated technology 

for these purposes and is considered BACT for the PEEC Project.
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1EPA-8 According to page 2-11 of the PSD application, the proposed project will include the 

installation and use of a natural gas-fired "construction 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 the 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. The 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 construction 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 engine, 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 Units

Fuel Gas Gas Gas ULSD OTurbine 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 7,171.0CO2e lb/hr 984,992 782,434 597,588 1,173,40

Net Output kW 1,330,432 1,017,017 731,608 1,006,65Net Heat Rate Btu/kWh (HHV) 6,325 6,572 6,978 7,122CO2e lb CO2e/MWh 740 769 817 1,166

Gas 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/Mwha 877 7% higher than estimated gas/oil

a 12-month rolling average

Estimated Performance
Table 1EPA-2-2. MPS "J" Estimated Performance and Proposed GHG BACT Limit (Gross Basis)

Category Units

Fuel Gas Gas Gas ULSD OiTurbine 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 1,173,407

Gross Output kW 1,372,005 1,052,444 761,474 1,044,07Gross Heat Rate Btu/kWh (HHV) 6,134 6,353 6,706 6,868CO2e lb CO2e/MWh 718 743 785 1,124

Gas 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/Mwha 847 7% higher than estimated gas/oil

a 12-month rolling average

Estimated Performance