Golder, Golder Associates and the GA globe design are trademarks o f Golder Associates Corporation



# BACT ANALYSIS FOR GREENHOUSE GAS EMISS IONS FROM NEW NATURAL GAS

- FIRED BOILER

New Hope Power Company Okeelanta Cogeneration Plant

Prepared For : New Hope Power Company

8001 U.S. Highway 27 South South Bay, FL 33493

Submitted By: Golder Associates Inc.

6026 NW 1st Place Gaines ville, FL 326 07 USA

Distribution: 4 copies

– EPA Region 4

1 cop y

– FDEP 2 copies

– New Hope Power Company 2 copies

– Golder Associates Inc.

February 2013 123

- 87582 PERMIT APPLICATIONFebruary 2013 i 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx 

# Table of Contents

1.0 INTRODUCTION

................................ ................................ ................................ .............................. 1

2.0 BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS FOR GHGS

................................ ....... 4

2.1 BACT Requirements

................................ ................................ ................................ .................... 4

2.2 Greenhouse Gases

................................ ................................ ................................ ...................... 5

2.2.1 Step 1

– Identification of Control Technologies

................................ ................................ ....... 5

2.2.2 Step 2

– Technical Feasibility

................................ ................................ ................................ .. 8

2.2.3 Step 3

– Rank Control Technologies by Control Effectiveness

................................ ............. 10

2.2.4 Step 4

– Evaluation of Economic, Environmental, and Energy Impacts o f Feasible Technologies

................................ ................................ ................................ .......................... 10

2.2.5 Step 5

– Selection of BACT and Rationale

................................ ................................ ............ 11

3.0 OTHER FEDERAL REQUIREMENTS

................................ ................................ ........................... 14

3.1 Endangered Species Act

................................ ................................ ................................ ............ 14

3.2 Coastal Zone Management Act

................................ ................................ ................................ .. 15

3.3 National Historic Preservation Act

................................ ................................ .............................. 16

3.4 Magnuson

- Stevens Fishery Conservation and Management Act

................................ .............. 17

3.5 Federal Land Manager

................................ ................................ ................................ ............... 17

3.6 Environmental Justice

................................ ................................ ................................ ................ 17

3.7 Tribal Consultation

................................ ................................ ................................ ..................... 18



### List of Tables

Table 2

- 1 Summary of GHG (CO 2 , CH 4 , N 2 O) BACT Determinations for L arge (> 250 MMBtu/hr)

Natural Gas

- Fired Boilers (2002

– 2012) Table 2

- 2 Summary and Ranking of GHG (CO 2 , CH 4 , N 2 O) Control Technologies



### List of Appendices
Appendix A Calculation of CO 2 Emissions From New Boiler D Appendix B Documentation of NHPC C ontacts with F ederal, S tate, and T ribal O fficialsFebruary 2013 1 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx 

### 1.0 INTRODUCTION
New Hope Power Company (NHPC) operates a 140

- megawatt (MW) net electric cogeneration facility located adjacent to the Okeelanta Corporation sugar mill and refinery , approximately 6 miles south of South Bay in Palm Beach County, Florida. The facility has three essentially identical cogeneration b oilers (Cogeneration Boilers A, B, and C) that combust primarily biomass (bagasse and wood) to generate steam and electricity. The cogeneration facility generates steam to produce electrical energy year

- round, but also supplies the adjacent sugar mill wit h process steam during the sugar cane grinding season, approximately October through March. The facility also supplies the Okeelanta sugar refinery with
process steam year

- round.

NHPC is proposing to add a fourth boiler, “ Boiler D ” , to the facility. Boiler D will be fired primarily with natural gas

, with No. 2 fuel oil used only as a backup fuel

. The new gas

- fired boiler will allow NHPC the flexibility to produce steam and electricity year

- round from all four boilers based on the most economical

fuel or fuel mix , using bagasse, wood, No. 2 fuel oil, and/or natural gas. The current maximum electrical generating capacity of the facility ( 140 net MW ) will not be increased with the addition of the new boiler.

B oiler D will have a maxi mum 1

- hour average heat input rate of 589 million British thermal units per hour (MMBtu/hr) and a maximum 24

- hour average heat input rate of 536 MMBtu/hr. The corresponding steam
production rates are 44 0,000 pounds per hour (lb/hr) as a 1

- hour average, an d 4 00,000 lb/hr as a 24

- hour

average. The new gas

- fired boiler will be permitted for 8,760 hours per year (hr/yr) operation.

The primary fuel for B oiler D will be natural gas

, with very low sulfur distillate fuel oil used as backup. The

distillate fuel o il will contain a maximum sulfur content of 0.05 percent. To control emissions of oxides of nitrogen (NO x ), t he boiler will use ultra l ow

- NO x burners for firing natural gas and distillate oil. The very

low sulfur content of the fuels utilized will control emissions of particulate matter (PM), sulfur dioxide (SO 2 ), mercury (Hg)

, and metals. A modern combustion system design and overfire air sy stem will control emissions of carbon monoxide (CO) and volatile organic compounds (VOC s ).

The construction of the new boiler requires an air construction permit and prevention of significant deterioration (PSD) approval. PSD approval requires the submiss ion of air quality assessments for determining the facility ’ s compliance with state and federal new source review (NSR) regulations. The critical aspects of these assessments include the air quality impact analyses performed using appropriate
air dispersi on models and the Best Available Control Technology (BACT) analyses that must be performed to evaluate the selected emission control technology.

The U.S. Environmental Protection Agency (EPA) has implemented regulations requiring a PSD review

for new and m odified sources with air emissions above certain threshold amounts. EPA ’ s PSD regulationsFebruary 2013 2 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx are promulgated under Title 40, Parts 52 and 51.166 of the Code of Federal Regulations ( 40 CFR 52 and

51.166 ) . Florida ’ s PSD regulations are codified in Rule 62

- 212 .400 of the Florida Administrative Code (F.A.C.). The Florida PSD regulations incorporate the requirements of EPA ’ s PSD regulations. The new natural gas

- fired boiler will be a “ major modification ” of a n existing major source under PSD rules.

Based on the potential emissions from B oiler D , PSD review is required for each of the following regulated
pollutants:

 NO x
 CO

 PM with an aerodynamic diameter less than or equal to 10 microns (PM 10 )

 PM with an aerodynamic diameter less than or equal to 2.5 microns (PM 2.5 )

 G reenhouse g ases (G HGs )

Palm Beach County has been designated as an attainment area for several criteria pollutants : PM 2.5 , SO 2 , CO, and nitrogen dioxide ( NO 2 ) . Palm Beach County is unclassifiable for PM 10 and lead (Pb), and a

maintenance area for ozone (O 3 ). Palm Beach County is a PSD Class II area for PM 10 , PM 2.5 , SO 2 , CO,

NO 2 , Pb, and VOC s

. Therefore, the PSD review for Boiler D will follow the regulations pertaining to these designations. For each pollutant subject to PSD review, the following analyses are required:

1. Ambient monitoring analysis, unless the net increase in emissions due to the modification causes impacts that are below specified significant impact levels (SILs)

2. Application of BACT for each new or modified emissions unit

3. Air quality impact analysis, unless the net increase in emissions due to the modification causes impacts that are below specified SIL s

4. Additional impact analysis (impact on soils, vegetation, visibility, and growth), including impacts on PSD Class I areas

The new boiler will be a minor source of hazardous air pollutants (HAPs) , but the NHPC facility is a major

source of HAPs

.

The Florida Department of Environmental Protection (FDEP) has been delegated PSD review authority in Florida for all PSD pollutants with the exception of GHGs. Because Florida has not yet adopted EPA ’ s PSD regulations related to GHG emissions, EPA retains PSD review authority for GHGs. EPA ’ s authority is contained in a Federal Implementation Plan (FIP) that became effective on Decemb er 30, 2010. The FIP includes the EPA PSD regulations contained in 40 CFR 52.21, including the PSD applicability provisions, but applies only to GHGs.February 2013 3 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx As a result, a PSD permit application for the new Boiler D has been submitted to the FDEP that addresses

NO x , CO, PM 10 , and PM 2.5 . A copy of the FDEP PSD application is being provided separately to EPA Region 4.

The PSD application for GHG emissions, which requires a BACT analysis , is contained in this report. The GHG BACT analysis is contained in Section 2.0. Compliance with other federal requirements , including the Endangered Species Act, is addressed in Section 3.0 of this report.February 2013 4 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx 

### 2.0 BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS FOR GHGS

2.1 BACT Requirements

The 1977 Clean Air Act ( CAA ) Amendments established requirements for the approval of pre

- construction permit applications under the PSD program. O ne of these requirements is that BACT be applied to pollutants that are subject to PSD review. This section presents the proposed BACT f or GHGs . The approach to the BACT analysis is based on the regulatory definitions of BACT, as well as consideration of

EPA ’ s current policy guidelines requiring a “ top

- down ” approach. A BACT determination requires a site

specific analysis of the technica l, economic, environmental, and energy impacts of the proposed and alternative control technologies [ 40 CFR 52.21 (b)(1 2)]

.

The “ top

- down ” approach consists of the following five steps, as described in the New Source Review
Workshop Manual

- Draft (EPA, 1990):

1) Identification of all available control technologies
2) Elimination of technically infeasible control options
3) Ranking of the tech nically feasible control technologies based on their effectiveness
4) Evaluation of the economic, environmental, and energy impacts of the feasible control options 5) Selection of BACT based on consideration of the above factors

For the proposed NHPC Boile r D p roject, PM/PM 10 /PM 2.5 , NO x , CO, and GHGs are subject to PSD review and as a result, BACT review is required for these pollutants. In each case, BACT is an emission limitation that meets the maximum degree of emission reduction after taking into accou nt the proposed

p roject ’ s specific economic, environmental, and energy impacts, while considering the application of the technologies proposed. If it is impractical to impose an emission limit, a work practice standard may be specified.

EPA has issued sev eral guidance documents addressing BACT for GHG emissions from electric utility and industrial combustion sources. These documents include the following:

 PSD and Title V Permitting Guidance for Greenhouse Gases, November 2010

 Available and Emerging Techno logies for Reducing Greenhouse Gas Emissions f rom Industrial, Commercial, and Institutional Boilers, October 2010

 Available and Emerging Technologies for Reducing Greenhouse Gas Emissions f rom Coal

- Fired Electric Generating Units, October 2010

 Proposed New Source Performance Standards (NSPS) for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units, 40 CFR 60, Subpart TTTT [ 77 Federal Register (FR) No. 72, pg. 22392, April 13, 2012 ]February 2013 5 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx The BACT analysis for Boiler D at NHPC fol lows these guidance documents. The following sections provide the required BACT analysis for GHGs

.



### 2.2 Greenhouse Gases
As part of the BACT analysis, a review was performed of previous GHG BACT determinations for similar
natural gas

- fired industrial and electric utility boilers listed in the RACT/BACT/LAER Clearinghouse on

EPA ’ s web page. EPA ’ s GHG permitting website was also reviewed. From this information, BACT determinations issued within the last 10 years (i.e., since 200 2 ) were identified. A summa ry of these BACT determinations is presented in Table 2

- 1

.

From the review of previous BACT determinations, there have only been three known BACT determinations for new natural gas

- fired boilers. GHG BACT determinations for new natural gas

- fired industria l and electric utility boilers have been based on clean (low

- carbon) fuels and energy efficiency improvements. Only one p revious BACT determination has a numerical emission limit, which is 117 pounds per million British thermal units ( lb/MMBtu )

. The othe r two BACT determination s are based on good combustion or good operating practices.



### 2.2.1 Step 1

– Identification of Control Technologies
In the BACT analysis, GHGs are considered as a single air pollutant, which is the aggregate group of the
six principal gases, carbon dioxide (CO 2 ), nitrous oxide (N 2 O), methane (CH 4 ), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6 ). The aggregate of these emissions is expressed

as CO 2 equivalents (CO 2 e). CO 2 emissions result from the oxidation of carbon in the fuel, CH 4 emissions result from incomplete combustion, and N 2 O emissions result primarily from low temperature combustion.

CO 2 , N 2 O, and CH 4 are the principal GHGs that will be emitted from the new nat ural gas

- fired boiler.

Emissions of CH 4 and N 2 O from natural gas

- fired boilers are extremely low

, and as a result, control options for these pollutants are not discussed.

EPA recommends that permit applicants and permitting authorities identify all “ avail able ” GHG control options that have the potential for practical application to the source under consideration. In the PSD and Title V Permitting Guidance for GHGs (EPA, 201 0 ), EPA emphasizes two mitigation approaches for CO 2 : energy efficiency and carbon capture and storage (CCS). The Guidance for GHGs also states that clean fuels, which would reduce GHG emissions, should be considered while recognizing at the same time that the BACT analysis does not need to include a clean fuel option that would fundame ntally redefine the

source.

In EPA ’ s “ Available and Emerging Technologies for Reducing Greenhouse Gas Emissions f rom Industrial,
Commercial, and Institutional Boilers ” (October 2010), a number of GHG reduction measures areFebruary 2013 6 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx identified. These include variou s energy efficiency improvements, post

- combustion techniques ( CCS ), and other measures such as fuel switching and combined heat and power applications.

GHG emission control options are discussed below.



### 2.2.1.1 Clean Fuel
The definition of BACT in 40 CFR 52.21(b)(1 2) includes use of clean fuels as a pollution control technique. The combustion of natural gas emits almost 30 percent less CO 2 than fuel oil, and just under 45 percent less CO 2 than coal (source: 40 CFR 98, Subpart C; www.naturalgas.org ). The proposed boiler will be fired primarily with natural gas, with No. 2 fuel oil used only as a backup fuel when natural gas is

not available

. Indeed, natural gas offers the lowest GHG emissio ns of all fuels available.



### 2.2.1.2 Energy Efficiency
Energy efficiency falls under the general category of lower

- polluting processes/practices. Applying technologies, measures, and options that are energy efficient translates not only to the reduction of

emission s of the particular regulated NSR air pollutant undergoing BACT review, but it also may achieve collateral reductions of emissions of other pollutants. There are different categories of energy efficient
improvements:

 Technologies or processes that maximiz e the efficiency of the individual emissions unit

 Replace/upgrade burners

 Tuning

 Optimization

 Instrumentation and controls

 Economizer

 Air preheater

 Insulation

 Reduce air leakages

 Capture energy from boiler blowdown

 Condensate return

 Reduce slagging and fou ling of heat transfer surfaces

 Insulating jackets

 Reduce steam trap leaks

 Options that could reduce emissions from a new green field facility by improving the utilization of thermal energy and electricity that is generated and used on site (i.e., combined heat and power)February 2013 7 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx When the efficiency of the steam generation and power generation process is increased, less fuel is burned to produce the same amount of steam and electricity. This provides the benefits of lower fuel costs and

r educed air pollutant emissions [ including CO 2 on a pound per megawatt

- hour ( lb/MW

- hr) basis]

. In addition, a boiler that is a cogeneration unit produces both electric energy and additional useful thermal energy, which adds significantly to the overall energy efficiency of the unit.



### 2.2.1.3 Carbon Capture and Storage
CCS falls under the category of add

- on controls, which are air pollution control technologies that remove pollutants from a facility ’ s emissions stream (flue gas) . As identified in EPA ’ s PSD and Title V Permitting

Guidanc e for Greenhouse Gases , EPA classifies CCS as an add

- on pollution control technology that is

“ available ” for large CO 2 - emitting facilities including fossil fuel

- fired power plants and industrial facilities with high

- purity CO 2 streams. As a result, EPA requires that CCS be considered in Step 1 of the BACT
analysis.

CCS is composed of three main components: CO 2 capture and/or compression, transport, and long

- term, perpetual storage.

Carbon Capture

– Before CO 2 gas can feasibly be stored, it must be captured as a relatively pure gas. Most power plants and other large point sources use air

- fired combustors, a process that exhausts CO 2 diluted with nitrogen. According to the U.S. Department of Energy, flue gas from the combustion of fossil fuels contains approximately 5 to 15 percent CO 2 . For effective carbon sequestration, the CO 2 in these exhaust gases must be separated and concentrated.

According to the Department of Energy ’ s National Energy Technology Laboratory (NETL), techn ologies for capturing CO 2 from relatively dilute streams such as those produced by power generation facilities are less common. These technologies currently include amine and chilled ammonia solvent systems, which

have been used with coal

- based power plan t applications.

The Carbon Sequestration Leadership Forum (CSLF), a ministerial

- level international climate change initiative comprised of 24 member nations representing over 60 percent of the world ’ s population, states:

“ Evolutionary improvements in exist ing CO 2 capture systems and revolutionary new capture and sequestration concepts will be needed to bring carbon capture costs down. ” The most likely options currently identifiable for CO 2 separation and capture include the following:

 Absorption (chemical and physical)

 Adsorption ( chemical and physical )

 Low

- temperature distillationFebruary 2013 8 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx

 Gas separation membranes

 Mineralization and biomineralization ( http://www.cslforum.org/education/index.h tml#inFocus )

Carbon Transport

– After the CO 2 is captured, it must be transported to a carbon sequestration site. Pipelines are the most common method for transporting large quantities of CO 2 over long distances. Shipping CO 2 via pipeline involves compre ssing gaseous CO 2 to a pressure above 1,160 pounds per square inch (psi), to increase CO 2 density and make it easier and less expensive to ship. A CO 2 pipeline would be similar to a high pressure natural gas pipeline. CO 2 also can be transported as a liq uid in seagoing vessels or via tankers on roads or railways. In these instances, the CO 2 is held in insulated tanks at low temperatures and relatively low pressures.

Carbon Storage

– In a CCS system, CO 2 is captured, transported if necessary, and then sto red. Geologic formations such as depleted oil and gas reservoirs, unmineable coal seams, and underground saline formations are potential options for long

- term storage. Pressurized CO 2 is injected into the deep geologic formations through drilled wells. Under high pressure, CO 2 turns to liquid and can move through a formation as a fluid. Once injected, the liquid CO 2 tends to be buoyant and will flow upward until it

encounters a barrier of non

- porous rock, which can trap the CO 2 and prevent further upwar d migration.

When CO 2 is injected into a coal seam, it is adsorbed onto the coal surfaces, and methane gas is released and produced in adjacent wells. This technology is available. There are other mechanisms for

CO 2 trapping as well: CO 2 molecules can d issolve in brine; react with minerals to form solid carbonates; or adsorb in the pores of porous rock.

Deep saline formations, which are layers of porous rock saturated with brine, present an enormous potential for geologic storage of CO 2 . However, the in dustry doesn ’ t have as much experience with saline formations as they have acquired through resource recovery from oil and gas reservoirs and coal seams. There is ongoing research focused on storage in organic rich shale, which is a thin horizontal layer of
sedimentary rock with low vertical permeability

, and in basalt formations, which are geologic formations of solidified lava. Other possible options include liquid storage in the ocean.



### 2.2.2 Step 2

– Technical Feasibility
Under the second step of the top

- down BACT analysis, all available control techniques listed in Step 1 may be eliminated from further consideration if they are not technically feasible for the specific source and unit under review. EPA considers a technology to be technically feasibl e if it has been demonstrated and operated successfully on the same type of source under review.February 2013 9 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx 

### 2.2.2.1 Clean Fuels
Use of clean fuels is considered to be a technically feasible GHG emission control option for the new
natural gas

- fired boiler. The proposed boile r will primarily fire pipeline quality natural gas , with No. 2 fuel

oil as backup , which are considered to be “ clean fuels ”

. Natural gas is considered to be the cleanest fuel
available, as its CO 2 e emissions are the lowest of any fossil fuel or biomass fu el. The use of No. 2 fuel oil

will also be limited to a maximum of 15 percent of the potential total heat input on an annual basis.



### 2.2.2.2 Energy Efficiency

Efficient steam generation and power generation is considered to be technically feasible for the new

natu ral gas boiler. Several techniques to improve energy efficiency were identified in S ubs ection 2. 2. 1.2.
However, some of th e se techniques are only applicable to existing steam generating units. The techniques applicable to new steam generating units (boi lers) are as follows:

 Efficient burner design

 Optimization

 Instrumentation and controls

 Economizer

 Air p reheater

 Insulation

 Capture energy from boiler blowdown

 Condensate return

 Reduce slagging and fouling of heat transfer surfaces

 Insulating jackets

 Reduce steam trap leaks



### 2.2.2.3 Carbon Capture and Storage

In the PSD and Title V P ermitting G uidance for GHGs, EPA states that it does not believe CCS will be a technically feasible BACT option in certain cases at this time. To establish that an option is techni cally feasible, the permitting record should show either that an available control option has been demonstrated
in practice or is available and applicable, with the term “ applicable ” generally meaning a technology can reasonably be installed and operated o n the source type under consideration. EPA recognizes the significant logistical hurdles that the installation and operation of a CCS system presents and that sets it
apart from other add

- on controls that are typically used to reduce emissions of other re gulated pollutants.

It should also be noted that while CCS may be available as identified in EPA ’ s PSD and Title V Permitting

Guidance for Greenhouse Gases (November 2010) , there are no CCS systems “ commercially available ”

for full

- scale power plants in th e United States. Logistical hurdles for CCS include appropriate geologicalFebruary 2013 10 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx formations within a reasonable distance, obtaining contracts for offsite land acquisition (including the availability of land), the need for funding (including, for example, government subsidies), timing of available transportation infrastructure, and deve loping a site for secure long term storage. Not every source has the resources to overcome the offsite logistical barriers necessary to apply CCS technology to
its operations, and smaller sources will likely be more constrained in this regard. Based on t hese considerations, a permitting authority may conclude that CCS is not applicable to a particular source, and consequently not technically feasible, even if the type of equipment needed to accomplish the compression, capture, and storage of GHGs are dete rmined to be generally available from commercial

vendors.

There are no known applications of CCS for controlling CO 2 emissions from boilers in Florida, and there is uncertainty as to the location of available and acceptable geologic formations for long

- ter m CO 2 storage. NHPC, being an independent cogeneration facility, does not have the financial resources required to implement CCS, and CCS if required would certainly render the project economically infeasible. Due to
lack of commercial demonstration, CCS is considered to be technically and economically in feasible for controlling the CO 2 emissions from the new natural gas

- fired boiler.



### 2.2.3 Step 3

– Rank Control Technologies by Control Effectiveness
Of the three potential control technologies discussed above , u se of clean fuels and energy efficiency
techniques are the technically feasible CO 2 control technologies (see Table 2

- 2 ) . Together, these technologies present the top CO 2 control options.



### 2.2.4 Step 4

– Evaluation of Economic, Environmental, and Energy Impacts of Feasible Technologies
Under Step 4 of the top

- down BACT analysis, economic, energy, and environmental impacts are evaluated for each option remaining under consideration. Energy efficiency improvements generally reduce emissions of all pollutants resul ting from combustion processes, so any energy efficiency improvements are desirable. The new natural gas

- fired boiler will be designed to maximize its thermal efficiency and will use clean fuels. Therefore, there are no additional economic impacts associ ated with
these options.

The CCS option was eliminated in Step 2 as not technically feasible for the project. Although EPA considers CCS as technically available, it is not commercially available. Indeed, EPA recognizes that at present, CCS is an expensi ve technology, largely because of the costs associated with CO 2 capture and compression. In the Guidance, EPA states that even if not eliminated in Step 2 of the BACT analysis, on the basis of the current costs, CCS is more likely to be eliminated from co nsideration in Step 4 of theFebruary 2013 11 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx BACT analysis, even in some cases where underground storage of the captured CO 2 near the facility is

feasible.



### 2.2.5 Step 5

– Selection of BACT and Rationale
The efficiency of the generation technology in producing steam and electric ity

, and the fuel utilized

, are the most important aspects in GHG emissions from industrial boilers and electric generation facilities. Together, efficiency and fuel type dictate the amount of GHG emissions per unit of steam production or

electrical gener ation.

The new natural gas

- fired boiler will be designed for a thermal efficiency of 85 percent. Although the specific boiler manufacturer has not yet been selected, the manufacturer will be required to supply a boiler with a minimum thermal efficiency of 85 percent. Energy efficiency measures incorporated i nto the
proposed Boiler D will include the following:

 Efficient burner design , consistent with ultra

- low NO x emissions

.  Optimization

– boiler operation will be optimized through the control system and initial tuning , and operated according to the manufacturer ’ s recommendations through a boiler

- specific Operation and Maintenance (O&M) Plan.

 Instrumentation and controls

– a modern digital control system includin g an oxygen or CO 2 monitor will be installed on the boiler

.  Economizer

– used to preheat boiler feedwater using boiler flue gas stream , which maximizes energy efficiency. Based on a design of other similar boilers, the temperature of the flue gas at the entrance of the economizer will be approximat ely 550 to 600 degrees Fahrenheit ( °F ) while the exit temperature will be 300°F or less.

 Insulation and refractory

– significant heat loss can occur through the boiler shell, especially for large boilers. The proposed new boiler will be properly insulated by the manufacturer to minimize the heat energy losses. The radiation losses are expected to be less than 1 percent at full load

, and less than 2 percent at 25

- percent load. This demonstrates that radiation losses will be minimal.

 Minimize a ir leakages

– NHPC will employ good maintenance practices to minimize air leakage du r ing operation. Operational monitoring will also be used to identify air leakage conditions and sources. This monitoring will be incorporated into the O&M Plan.

 Capture energy from boiler blowdown

– boiler 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 percent of the steam rate is a good candidate for considering blowdown waste heat recovery. The new natural gas

- fired boiler is expected to have a design continuous blowdown of less than 5 percent

.  Condensate return system

– the new boiler ’ s makeup water system will be incorporated into the existing makeup water system for the existing three cogeneration boilers.February 2013 12 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx

This will take advantage of systems already in place to recover energy fr o m the condensate.

 Reduce slagging and fouling of heat transfer surfaces

– primarily through use of natural gas fuel

.  Steam line design and maintenance

– appropriate measures will be included in the O&M Plan.

The boiler will also be operated very efficiently using clean fuels such as natural gas and low

- sulfur fuel

oil. An O&M Plan will be developed prior to boiler startup which will include measures to m inimize the deterioration in boiler efficiency over time. The natural gas

- fired boiler at NHPC will be brand new and specifically designed for its intended use at NHPC. Although some deterioration in the design efficiency
of the boiler is expected to occ ur over time, based on the history of maintenance and operation at Okeelanta Cogeneration facility, the deterioration is expected to be minimal. Equipment deterioration
primarily occurs over time with continued use. NHPC will schedule sufficient time for maintenance of the
new boiler each year to minimize equipment deterioration over time.

In addition to the above measures , the boiler will be operated to produce both electrical energy and useful thermal energy, enhancing the energy efficiency of the unit. This measure will constitute the most significant energy efficiency method employed by the new boiler. The steam from the boiler is first sent through electric turbine generators, where electricity is generated. The steam discharging from the turbine g enerators, now at a lower pressure and temperature, is then sent to the Okeelanta sugar mill and refinery to provide useful thermal energy to the sugar production process.

Based on the above measures which will be implemented as BACT, no additional improve ments in energy efficiency are necessary. Air preheat is a technique typically used in much larger boilers

, such as

th ose used in the electric utility industry

, with heat inputs in excess of 1,000 MMBtu/hr and twice as large at the proposed natural gas

- fi red boiler. The proposed boiler will have a design efficiency of more than

80 percent

. Installation of an air preheater is not practical for this boiler. An air preheater would also
impose additional pressure loss on the system.

Natural gas will be used as the primary fuel in the proposed boiler, with No. 2 fuel oil as a backup fuel. This is consistent with the definition of BACT, which states that a design, equipment, work practice, operational standard, or combination thereof, may be prescribed instea d to satisfy the requirement for the application of best available control technology.

NHPC has performed a calculation of Boiler D ’ s projected CO 2 emission in terms of lb/MW

- hr ( Appendix A )

, using standard CO 2 emission factors for natural gas and No. 2 fu el oil. The calculations take into accountFebruary 2013 13 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx a margin to account for an actual boiler efficiency less than the selected boiler manufacturer ’ s guarantee d efficiency NHPC has assumed, and also to account for efficiency degradation over the life of the boiler.

Boiler D will operate during the sugarcane processing season along with the other three existing NHPC

biomass

- fired boilers. During the off

- season, Boiler D will operate along with one other existing NHPC

biomass

- fired boiler. The electrical generation and useful thermal output of Boiler D will be different under these two operating regimes. Under the crop season operating regime, Boiler D maximum CO 2 emissions

are estimated at 825 lb/MW

- hr while firing natural gas, and 1,151 lb/MW

- hr while firing No. 2 fuel oil.

Under the off

- season operating regime, Boiler D maximum CO 2 emissions are estimated at 848 lb/MW

- hr while firing natural gas, and 1,184 lb/MW

- hr when firing No. 2 fuel oil.

As shown in Appendix A, the overall CO 2 limit, assuming 150 crop season days and 215 off

- crop days, as

well as the worst case of 85 percent natural gas firing and 1 5 percent No. 2 fuel oil firing, is 8 88 lb/MW

- hr.

PSD regulations also require that BACT for a source cannot be less stringent than any federal new
source performa nce standard (NSPS). On April 13, 2012, EPA proposed NSPS for Greenhouse Gas Emissions from Electric Utility Generating Units (77 FR No. 72, pg. 22392). The regulation would be codified in 40 CFR 60, Subpart TTTT. The proposed rule sets a CO 2 (note: not CO 2 e) emission limit from all new electric utility generating units of 1,000 lb/MW

- hr , 12

- month rolling average . This limit is proposed regardless of fuel type, and therefore would apply to the proposed Boiler D regardless of fuel type. As

shown above a nd in Appendix A

, Boiler D CO 2 emissions are well below the proposed NSPS limit of

1 ,000 lb/MW

- hr.February 2013 14 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx 

### 3.0 OTHER FEDERAL REQUIREMENTS
In addition to the CAA requirements

, there are requirements in four other statutes that sometimes must be met before a source can begin construction and operation under a PSD permit. As discussed further below, the other statutory requirements that may apply to the project are the Endangered Species Act (ESA), the Coastal Zone Management Act (CZMA), t he National Historic Preservation Act (NHPA), and
the Magnuson

- Stevens Fishery Conservation and Management Act (MSFCMA). Environmental justice and tribal consultation must also be addressed as required by Executive Orders (EO s ).

The permit applicant , thro ugh Golder Associates Inc., initiat ed contact with the EPA Region 4 Office in
December 2012, and then with other implementing federal departments or agencies, state agencies, and

tribal officials for these statutes to determine appropriate contacts and spe cific requirements that may apply

to the proposed project. NHPC ’ s contacts with the EPA and other federal, state, or tribal officials are

documented in Appendix B . NHPC ’ s assessment of the applicability of these statutory requirements is
presented in the sections below

. This includes specific information needed from NHPC that is identified below for the four statutes, and any additional information that was requested by the EPA.



### 3.1 Endangered Species Act

Under Section 7(a)(2) of the ESA, 16 U.S.C. § 1536(a)(2), the EPA must ensure that any action authorized, funded, or carried out by the EPA is not likely to jeopardize the continued existence of any federally listed endangered species or threatened species or result in the destruction or adverse

modif ication of such species ’ designated critical habitat. If the EPA ’ s action (i.e., permit issuance) may affect a federally listed species or designated critical habitat, Section 7(a)(2) of the ESA and relevant implementing regulations at 50 C F R 402 require consultation between the EPA and the U.S. Fish and Wildlife Service (FWS) and/or the National Marine Fisheries Service (NMFS), depending on the species

at issue. After first contacting the EPA Regional Office to discuss the process, applicants should cont act the FWS (and/or NMFS, if applicable) to ask whether there are any species or critical habitats listed or designated, or proposed for listing or designation, in the action area.

The NHPC site is located in the Everglades Agricultural Area (EAA), just so uth of Lake Okeechobee. The area surrounding NHPC is all agricultural area, primarily plant ed in sugarcane, with some sod and vegetable farms. The nearest national preserves or national parks are the Big Cypress National
Preserve, located about 25 miles southwest

, and the Everglades National Park

, located about 55 miles

south

- southwest of the NHPC site. The Loxahatchee National Wilderness Area is located about 20 miles

due east of the NHPC site. There are federally

- listed threatened and endangered speci es in the Big Cypress Preserve and the Everglades National Park. Some of these may also be present in the

Loxahatchee NWA.February 2013 15 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx NHPC submitted a Site Certification Application (SCA) to the FDEP in August 2004 for an expansion of its
electrical generating capac ity. This application was approved on May 17, 2005, and Conditions of

Certification No. PA 04

- 46 were issued. The SCA stated that no critical habitat of endangered species
existed within 5 miles [ 8 kilometers ( km) ] of the NHPC site.

Nevertheless, the pre dicted air quality impacts of the proposed new natural gas

- fired boiler, presented in the FDEP air construction permit application, demonstrate that there will not be a significant air quality impact on these areas due to the proposed project. Air Quality Related Values (AQRVs) in the Everglades National Park will not be adversely affected. The modeling analysis demonstrated that the maximum
impacts due to the proposed project are less than the EPA SIL s for all pollutants and averaging times, except for 1

- hour NO 2 concentrations. For 1

- hour NO 2 , concentrations fall below the SIL s within 5 km of the NHPC facility.

As a result, no adverse effects to any threatened or endangered species which might be pres ent near the facility are expected.

NHPC has initiated contact with the FWS and NMFS offices in the area to ask whether there are any species or critical habitats listed or designated, or proposed for listing or designation, in the action area.
Further, N HPC requested a determination of any significant impact to endangered species due to the
proposed project.



### 3.2 Coastal Zone Management Act

The CZMA encourages states to preserve, protect, develop, and where possible, restore or enhance

valuable natural coastal resources such as wetlands, floodplains, estuaries, beaches, dunes, barrier islands, and coral reefs, as well as the fish and wildlife using those habitats. It includes areas bordering the Atlantic, Pacific, and Arctic Oceans, the Gulf of Mexico, Long Is land Sound, and the Great Lakes.

In any application for a PSD permit for a facility located in a state ’ s coastal zone (or outside the state ’ s coastal zone but affecting any land or water use or natural resource of the coastal zone), the applicant
should pr ovide the EPA Regional Office with the applicant ’ s own certification that the proposed activity complies with the enforceable policies of the state ’ s NOAA

- approved coastal program and that such

activities will be conducted in a manner consistent with that program. The applicant also furnishes the

state coastal zone management agency a copy of the certification, with necessary data and information.

The state agency may concur or object to the consistency dete r mination. The Regional Office cannot

issue the license or permit until the state agency concurs in the certification or, through the state ’ s failure
to act, its concurrence can be conclusively presumed.February 2013 16 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx The NHPC site is located well inland of either the east coast or west coast of Florida. The east c oast is located approximately 45 miles east of the site, while the we st coast is approximately 70 miles west of the

site. T he FDEP application demonstrates that the proposed project will not affect any land or water use

or natural resource along the coast of Florida

.

NHPC has initiated contact with the NMFS office in the area to determine if the NHPC site is within the coastal zone, and if so, whether the project is consistent with Florida’s coastal zone management plan.



### 3.3 National Historic Preservation Act

Section 1 06 of the NHPA requires the EPA

, prior to the approval of the expenditure of any funds on, or prior to the issuance of any license for, an undertaking

, to take into account the effects of its undertakings on historic properties and afford the Advi sory Council on Historic Preservation (the Council) a reasonable
opportunity to comment with regard to such undertakings (1 6 U.S.C. §470f )

. Under the Council ’ s implementing regulations at 36 CFR 800, S ection 1 06, consultation is required for all unde rt aki ngs that have the potential to affect historic properties. Section 106 consultations assess whether historic
properties exist within an undertaking ’ s area of potential effect and, if so, whether the undertaking will adversely affect such properties. Consultation is generally with relevant state and tribal historic preservation authorities in the first instance, with opportunities for direct Council involvement in certain

circumstances.

The term “ historic properties ” means prehistoric or historic distr icts, sites, buildings, structures, or objects included in, or eligible for inclusion in, the National Register of Historic Places maintained by the Department of the Interior. Historic properties include properties of traditional religious and cultural

i mportance to an Indian Tribe or Native Hawaiian organization.

NHPC submitted a SCA to the FDEP in August 2004 for an expansion of its electrical generating capacity. This application was approved on May 17, 2005, and Conditions of Certification No. PA 04

- 46 were issued. The SCA stated that a review of the State of Florida Master Site File (FMSF) was undertaken to determine if known archaeological or hist oric sites have been recorded for the NHPC site or adjacent
properties. The FMSF search revealed that no archeological sites had been recorded on the NHPC site. Further, a letter was sent to the Florida Department of State, Division of Historical Resources (DHR) in 1993 requesting DHR to determine whether undiscovered archaeological or historical resource s were likely to be present in the vicinity of the NHPC plant, and whether a pedestrian survey would be required.
DHR responded and determined that:

 No significant archaeological or historical sites are recorded for or considered likely to be present in t he project areaFebruary 2013 17 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx

 Because of the project location and/or nature, it is unlikely s uch sites would be affected

 It was the opinion of DHR that the project would have no effect on historic properties listed or eligible for listing in the Natio nal Register of His toric Places

As a result, no adverse effects on any historical sites are expected due to operation of the proposed natural gas

- fired boiler

.

NHPC has initiated contact with the EPA Region 4 office to ask whether there are impacts upon historical

sites due to the proposed project.



### 3.4 Magnuson

- Stevens Fishery Conservation and Management Act

The MSFCMA was enacted to promote the U.S. fishing industry ’ s optimal exploitation of coastal fisheries by consolidating control over territorial waters to manage fish stocks

. Implementation of the MSFCMA is by the U.S. Department of Commerce, NMFS, and its appointed regional fishery management councils.

A s part of the permit review process, the EPA Regional Office should discuss the project with the NMFS

.

As described in Se ction 3.2 , the NHPC site is located well away from coastal areas, and therefore will not impact coastal fisheries. NHPC has initiated contact with the NMFS offices in the area to ask whether the
proposed project would violate any provision of the MSFCMA

.



### 3.5 Federal Land Manager

The EPA ’ s policy is that the Federal Land Manager ( FLM ) should be notified by the EPA Regional Office
about any project that is located within 1 00 km of a PSD Class I area. The FDEP air permit application
addresses air impacts as well as AQRVs in the Class 1 area ( E verglades National Park). The assessment

demonstrates there will be no adverse e ffects due to the proposed project. NHPC has initiated contact with the FLM and FWS to request a determination of any adverse impacts on the P SD Class I area due to
the proposed project.



### 3.6 Environmental Justice

EO 12898 provides for federal agencies to identify and address disproportionately high and adverse effects of their actions on minority, low

- income, and tribal populations. The EPA defines environmental
justice to include the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income in environmental decisions that affect them.

The NHPC site is an existing site that has been in operation si nce 1996. The only nearby towns or cities are South Bay and Belle Glade. Due to the very low impacts of the proposed natural gas

- fired boiler,February 2013 18 123

- 87582

Y: \ Projects \ 2012 \ 123

- 87582 NHPC PSD \ EPA (GHG) \ Final \ NHPC EPA GHG Rpt.docx there will be no new impacts associated with the proposed project. Therefore, the proposed project will

not di sproportionately affect any minority, low

- income, or tribal community.



### 3.7 Tribal Consultation

Under EO 13175

, if the proposed project may affect tribal interests, the EPA Regional Office should initiate consultation with the affected tribe(s) sufficiently ear ly in the process to allow for meaningful input by the tribe(s). In accordance with the Regional Office ’ s consultation plans and practices, the Regional Office should engage in such consultation prior to taking actions or implementing decisions that may

a ffect the tribes.

The nearest known Indian tribes to the NHPC site are the Big Cypress Indian Reservation, located about
20 miles southwest of the NHPC site, and the Miccosukee Indian Reservation, located about 25 miles south of the site. Again, due to th e very low impacts predicted for the propose d NHPC project, the project should have no effect upon tribal interests.

### TABLESFebruary 2013 123-87582

Table 2-1. Summary of GHG (CO 2 , CH 4 , N 2 O) BACT Determinations for Large (> 250 MMBtu/hr) Natural Gas-Fired Boilers (2002 - 2012)

RBLCID Company Name - Facility Name State Permit Number Permit Date Process Name Pollutant Control Method

*FL-0330 Port Dolphin Energy LLC FL DPA-EPA-R4001 12/1/2011 Boilers (4) 278 MMBtu/hr Carbon Dioxide 117 lb/MMBtu Tuning, Optimization, Instrumentation and Controls, Insulation, and Turbulent Flow

LA-0254 Entergy Louisiana LLC - Ninemile Point

Electric Generating Plant LA PSD-LA-752 8/16/2011 Auxiliary Boiler 338 MMBtu/hr Carbon Dioxide 117 lb/MMBtu (8-hr rolling avg) Proper Operation and Good Combustion Practices

Methane 0.0022 lb/MMBtu Proper Operation and Good Combustion Practices Nitrous Oxide 0.0002 lb/MMBtu Proper Operation and Good Combustion Practices Consolidated Environmental Management- LA PSD-LA-751 11/8/2010 Auxiliary Boilers (2) Carbon Dioxide N/A Good combustion practices to maintain low fuel consumption Nucor Steel Louisiana (prelim det) Throughput Emission Limit

Y:\Projects\2012\123-87582 NHPC PSD\EPA (GHG)\Final\NHPC EPA Section 2 Tables.xlsxFebruary 2013 123-87582

Table 2-2. Summary and Ranking of GHG (CO 2 , CH 4 , N 2 O) Control Technologies

PM Abatement Method Technique Now Available Estimated Efficiency Feasible and

Demonstrated? (Y/N) Rank Based on

Control Efficiency Employed by

NHPC Boiler? (Y/N)

Clean Fuel Fuel Substitution NA Y 1 Y
Energy Efficiency Good Design 10 - 50% Y 2 Y
Carbon Capture & Storage Capture, Transport & Storage >99% NTF NTF N

Note: NTF = Not Technically Feasible.

a Technically feasible for fluidized bed boiler only.

Y:\Projects\2012\123-87582 NHPC PSD\EPA (GHG)\Final\NHPC EPA Section 2 Tables.xlsx

### APPENDIX A

CALCULATION OF CO 2 

### EMISSIONS FROM NEW BOILER DFebruary 2013 123-87582

Appendix A Calculation of CO 2 Emissions From New Boiler D - Natural Gas Firing

Scenario assumes steam sent to Mill, which is used by the Mill to generate an additional 7 MW of electrical energy, is not counted

.

Natural Gas Boiler Data

Net enthalpy = 1,138 Btu/lb Steam Rate (full load) = 400,000 lb/hr steam

Efficiency = 85 %

Heat Input = 536 MMBtu/hr

CO 2 emission factor = 53.02 kg/MMBtu

CO 2 @ 400,000 lb/hr steam = 62,541 lb CO 2 /hr
CO 2 @ 300,000 lb/hr steam = 46,906 lb CO 2 /hr
CO 2 @ 120,000 lb/hr steam = 18,762 lb CO 2 /hr

Crop Season Operation (Natural gas boiler provides 300,000 lb/hr steam)

Gross Electrical output = 17.5 MW (1,200,000 lb/hr steam from all boilers generates 70 MW) NG boiler's portion of this is 70 MW x (300,000/1,200,000) Useful thermal output to Mill: High pressure steam = 67,500 lb/hr All boilers generate 270,000 lb/hr of HP steam to Mill not

Enthalpy = 1,336 Btu/lb used for electrical energy production: Heat output = 90.2 MMBtu/hr NG boiler's portion of this is 270,000 x (300,000/1,200,000)

Low pressure steam = 97,500 lb/hr All boilers generate 390,000 lb/hr of LP steam to Mill and Refinery;

Enthalpy = 1,177 Btu/lb NG boiler's portion of this is 390,000 x (300,000/1,200,000) Heat output = 114.8 MMBtu/hr

Total useful thermal output = 204.9 MMBtu/hr

= 60.1 MW

Total Gross Output = 62.6 MW (gross elect. + 75% of thermal)

CO 2 emissions = 750 lb CO 2 /MWh

Off-Season Operation (Natural Gas Boiler provides 120,000 lb/hr steam)

Gross Electrical output = 8.8 MW (300,000 lb/hr steam from all boilers generates 22 MW) NG boiler's portion of this is 22 MW x (120,000/300,000) Useful thermal output to Mill:

High pressure steam = 0 lb/hr No HP steam is sent to mill during off-season

Enthalpy = 1,336 Btu/lb Heat output = 0.0 MMBtu/hr

Low pressure steam = 60,000 lb/hr All boilers generate 150,000 lb/hr of LP steam to Refinery;

Enthalpy = 1,177 Btu/lb NG boiler's portion of this is 150,000 x (120,000/300,000) Heat output = 70.6 MMBtu/hr

Total useful thermal output = 70.6 MMBtu/hr

= 20.7 MW

Total Gross Output = 24.3 MW (gross elect. + 75% of thermal)

CO 2 emissions = 771 lb CO 2 /MWh

Y:\Projects\2012\123-87582 NHPC PSD\EPA (GHG)\Final\NHPC Blr D Appx A - CO2 Limits.xlsxFebruary 2013 123-87582

Appendix A Calculation of CO 2 Emissions From New Boiler D- No. 2 Fuel Oil Firing

Scenario assumes steam sent to Mill, which is used by the Mill to generate an additional 7 MW of electrical energy, is not counted

.

Natural Gas Boiler Data

Net enthalpy = 1,138 Btu/lb Steam Rate (full load) = 400,000 lb/hr steam

Efficiency = 85 %

Heat Input = 536 MMBtu/hr

CO 2 emission factor = 73.96 kg/MMBtu

CO 2 @ 400,000 lb/hr steam = 87,242 lb CO 2 /hr
CO 2 @ 300,000 lb/hr steam = 65,431 lb CO 2 /hr
CO 2 @ 120,000 lb/hr steam = 26,173 lb CO 2 /hr

Crop Season Operation (Natural gas boiler provides 300,000 lb/hr steam)

Gross Electrical output = 17.5 MW (1,200,000 lb/hr steam from all boilers generates 70 MW) NG boiler's portion of this is 70 MW x (300,000/1,200,000) Useful thermal output to Mill: High pressure steam = 67,500 lb/hr All boilers generate 270,000 lb/hr of HP steam to Mill not

Enthalpy = 1,336 Btu/lb used for electrical energy production: Heat output = 90.2 MMBtu/hr NG boiler's portion of this is 270,000 x (300,000/1,200,000)

Low pressure steam = 97,500 lb/hr All boilers generate 390,000 lb/hr of LP steam to Mill and Refinery;

Enthalpy = 1,177 Btu/lb NG boiler's portion of this is 390,000 x (300,000/1,200,000) Heat output = 114.8 MMBtu/hr

Total useful thermal output = 204.9 MMBtu/hr

= 60.1 MW

Total Gross Output = 62.6 MW (gross elect. + 75% of thermal)

CO 2 emissions = 1,046 lb CO 2 /MWh

Off-Season Operation (Natural Gas Boiler provides 120,000 lb/hr steam)

Gross Electrical output = 8.8 MW (300,000 lb/hr steam from all boilers generates 22 MW) NG boiler's portion of this is 22 MW x (120,000/300,000) Useful thermal output to Mill:

High pressure steam = 0 lb/hr No HP steam is sent to mill during off-season

Enthalpy = 1,336 Btu/lb Heat output = 0.0 MMBtu/hr

Low pressure steam = 60,000 lb/hr All boilers generate 150,000 lb/hr of LP steam to Refinery;

Enthalpy = 1,177 Btu/lb NG boiler's portion of this is 150,000 x (120,000/300,000) Heat output = 70.6 MMBtu/hr

Total useful thermal output = 70.6 MMBtu/hr

= 20.7 MW

Total Gross Output = 24.3 MW (gross elect. + 75% of thermal)

CO 2 emissions = 1,076 lb CO 2 /MWh

Y:\Projects\2012\123-87582 NHPC PSD\EPA (GHG)\Final\NHPC Blr D Appx A - CO2 Limits.xlsxFebruary 2013 123-87582

Appendix A Performance and Proposed GHG BACT Limit (Gross Basis)

Category Units

Season Fuel Gas Oil Gas Oil Heat Input MMBtu/hr (HHV) 536 536 536 536 CO 2 lb/hr 46,906 65,431 18,762 26,173 Gross Output MW 62.55 62.55 24.32 24.32 Gross Heat Rate Btu/kWh (HHV) 8,562 8,562 22,016 22,016

CO 2 lb CO 2 /MWh 750 1,046 771 1,076

Average On/Off Season lb CO 2 /MWh 750 1,046 771 1,076 Margin for Guarantee % 5% 5% 5% 5% Margin for Degradation % 5% 5% 5% 5%

Proposed CO 2 lb CO 2 /MWh a 825 1,151 848 1,184

Season Days Days 150 150 215 215 Fuel Percentage % 85% 15% 85% 15%
12-Month Average lb CO 2 /MWh b

a Crop Season of Off Season averages.

b 12-month rolling average. Estimated Performance

Crop Season Off Season

888

Y:\Projects\2012\123-87582 NHPC PSD\EPA (GHG)\Final\NHPC Blr D Appx A - CO2 Limits.xlsx

### APPENDIX B

DOCUMENTATION OF NHPC CONTACTS WITH FEDERAL, STATE, AND TRIBAL OFFICIALS

### U.S. FISH & WILDLIFE SERVICE1 From: Sealey, Kristen Sent: Wednesday, January 30, 2013 4:13 PM To: victoria_foster@fws.gov Cc: Buff, Dave; Cobb, Phil Subject: PSD Greenhouse Gas Emissions Notification - New Hope Power Company, Florida Attachments: 123-87582_NHPC Project Desc for Agencies.pdf



### Hello Ms. Foster,

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 capa city 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 re quirements 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 th e 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 th is 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.

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 m edia 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.1 From: Sealey, Kristen Sent: Wednesday, January 30, 2013 4:07 PM To: jill_webster@fws.gov Cc: Buff, Dave; Cobb, Phil Subject: PSD Greenhouse Gas Emissions Notification - New Hope Power Company, Florida Attachments: 123-87582_NHPC Project Desc for Agencies.pdf



### Hello Ms. Webster,

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 capa city 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 re quirements 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 th e 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 th is 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.

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 m edia 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.

### NATIONAL PARK SERVICE1 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 Attachments: 123-87582_NHPC Project Desc for Agencies.pdf



### 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 capa city 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 re quirements 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 th e 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 th is 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.

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 m edia 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.

### NOAA / NATIONAL MARINE FISHERIES SERVICE1 From: Sealey, Kristen Sent: Wednesday, January 30, 2013 4:10 PM To: david.bernhart@noaa.gov Cc: Buff, Dave; Cobb, Phil Subject: PSD Greenhouse Gas Emissions Notification - New Hope Power Company, Florida Attachments: 123-87582_NHPC Project Desc for Agencies.pdf



### Hello Mr. Bernhart,

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 capa city 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 re quirements 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 th e 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 th is 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.

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 m edia 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.