PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 1

***PUBLIC NOTICE COPY***

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region 4 

Atlanta, Georgia 

Prevention of Significant Deterioration Permit 

For Greenhouse Gas Emissions

Permit PSD-EPA-R4014

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

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

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

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

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

Protection Agency Region 4 hereby authorizes:

Tampa Electric Company

PO Box 111

Tampa, FL 33601-0111

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

existing Polk Power Station located at 9898 State Road 37 South, Mulberry (Polk County), 

Florida.

This modification to the Polk Power Station shall be constructed and operated in accordance with 

the terms and conditions set forth in this permit.

This permit becomes effective on [INSERT EFFECTIVE DATE].

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

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

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

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

law.

__________ ______________________

Date Signed Carol L. Kemker

Acting Director

Air, Pesticides, and Toxics

Management Division
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 2

AUTHORITY

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

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

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

This permit is based upon application materials submitted to the EPA by Tampa Electric 

Company (TECO), dated October 2012; December 19, 2012; April 15, 2013; and May 3, 2013;

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

technical analysis performed by the EPA.

APPLICANT

Tampa Electric Company

PO Box 111

Tampa, FL 33601-0111

PROJECT LOCATION

TECO’s project will be located at the existing Polk Power Station located at 9898 State Road

37 South, Mulberry (Polk County), Florida.

PROJECT DESCRIPTION

TECO will modernize the existing Polk Power Station (PPS) by adding higher-efficiency, loweremission combined cycle technology (Project) to the four (4) existing simple cycle combustion 

turbines (CTs). The Project will increase the total nominal capacity of these units from 660 to 

1,160 megawatts (MW) and the total generating capacity of the PPS site to a nominal 1,420 MW 

(all net values). 

PPS currently consists of a nominal 250 MW (net) solid fuel-based, integrated gasification and 

combined cycle plant in addition to the simple cycle CTs. The existing facility is authorized to 

operate pursuant to Florida Department of Environmental Protection (FDEP) title V operating 

permit No. 1050233-026-AV. The Project will modify the simple cycle CTs to add combined 

cycle operation in a 4-on-1 configuration consisting of: four (4) General Electric 7FA.03 CTs, 

each a nominal 165 MW (net) output; four (4) heat recovery steam generators (HRSGs), each 

equipped with duct burners; and one (1) nominal 500 MW (net) output steam turbine generator 

(STG). The HRSGs will utilize the waste heat from the CTs as well as natural gas-fired duct 

burners to produce steam to be utilized in the STG. Other equipment include: a six-cell 

mechanical draft cooling tower, a 500 kilowatt (kW) ultra-low sulfur diesel (ULSD) fuel oil-fired 

emergency generator engine, a new transmission line, and existing line upgrades.

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

to limit emissions of GHGs, to the greatest extent feasible.
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 3

EQUIPMENT LIST

The following devices and activities are subject to this PSD permit:

Unit ID Description

CTs/HRSGs with 

Duct Burners (4)

 165 MW (net) simple cycle CTs

 1,160 MW (net) combined cycle CTs utilizing a 500 MW (net) STG in 

a 4-on-1 configuration

 Maximum combined heat input rate of 8,924 million British thermal 

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

Emergency 

Generator  500 kW; ULSD fuel oil-fired

STG  500 MW (net) output

Circuit Breakers

(18)

 Totally-enclosed pressure systems containing sulfur hexafluoride (SF6)

 0.5 % per year (by weight) annual leakage rate

 Leak detection system

Natural Gas

Component Leaks

 Fugitive GHG emissions (methane) resulting from leaks from piping 

components delivering natural gas to the duct burners of the HRSGs 

PERMIT CONDITIONS

I. PERMIT EXPIRATION

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

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

approval takes effect; or

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

C. is not completed within a reasonable time. 

II. PERMIT NOTIFICATION REQUIREMENTS

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

Region 4 of the:

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

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

of such date; and
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 4

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

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

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

required pursuant to Condition IX.E.

III. FACILITY OPERATION

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

Permittee shall, to the extent practicable, maintain and operate the facility, including 

associated air pollution control equipment, in a manner consistent with good air 

pollution control practice for minimizing emissions. Determination of whether 

acceptable operating and maintenance procedures are being used will be based on 

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

monitoring results, opacity observations, review of operating maintenance procedures 

and inspection of the facility. 

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

manner consistent with good engineering practices for its full utilization.

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

40 CFR § 60.2) but prior to commencement of commercial operation (as defined in 

40 CFR § 72.2), and thereafter, the Permittee shall develop and implement an 

operation and maintenance plan for the facility, consistent with Condition III.B

above. At a minimum, the plan shall identify measures for assessing the performance 

of the facility, the acceptable range of the plant performance measures for achieving 

the design electrical output, the methods for monitoring the plant performance 

measures, and the routine procedures for maintaining the facility in good operating 

condition.

IV. MALFUNCTION REPORTING

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

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

the discovery of any failure of air pollution control equipment or process equipment, 

or failure of a process to operate in a normal manner, which results in an increase in 

emissions above the allowable emission limits stated in Condition IX of this permit.

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

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

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

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

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

failure, the cause of the failure, the estimated resultant emissions in excess of those 
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 5

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

mitigate emissions and restore normal operations. 

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

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

malfunction may cause.

V. RIGHT OF ENTRY

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

presentation of credentials, shall be permitted:

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

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

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

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

C. to inspect any equipment, operation, or method subject to requirements in this PSD 

permit; and

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

VI. TRANSFER OF OWNERSHIP

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

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

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

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

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

within thirty (30) days of its issuance.

VII. SEVERABILITY

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

is held invalid, the remainder of this PSD permit shall not be affected.
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 6

VIII. ADHERENCE TO APPLICATION AND COMPLIANCE WITH OTHER 

ENVIRONMENTAL LAWS

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

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

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

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

laws and regulations, including the Clean Air Act.

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

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

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

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

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

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

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

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

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

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

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

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

872.05, Florida Statutes.

IX. SPECIAL CONDITIONS

A. Air Pollution Control Equipment and Operation 

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

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

B. Combustion Turbine Emission and Operational Limits and Work Practices

1. For maximized efficiency, the Permittee shall:

a. For the CTs: use inlet cooling, perform periodic burner tuning, insulate the unit, and 

utilize instrumentation/controls to achieve high-efficiency/low-emissions 

performance; and 

b. For the HRSGs: utilize efficient heat exchanger design, insulate all gas path surfaces 

exposed to ambient air, perform periodic cleaning of heat exchanger surfaces, and 

minimize steam venting and timely repair of steam leaks.
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 7

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

CT unit into the atmosphere in excess of the following:

Operating Scenario GHG Emission Limit1

(per CT on gross output basis) 

Combined Cycle/Natural Gas

(with or without Duct Burners)

877 pounds (lb) of carbon dioxide equivalent 

(CO2e) per megawatt-hour (MWh)

(12-month rolling average)

Combined Cycle/ULSD Fuel Oil 1,235 lb CO2e/MWh

(3-hour rolling average)

Simple Cycle/Natural Gas 1,320 lb CO2e/MWh

(3-hour rolling average)

Simple Cycle/ULSD Fuel Oil 1,868 lb CO2e/MWh

(3-hour rolling average)

1Compliance with the above limits shall be demonstrated in accordance with Condition IX.D.10.

3. The duct burners (of each HRSG) shall be limited to 4,000 hours per 12-month rolling 

period (as an average across the four HRSGs). Permittee shall monitor and record the 

number of hours the duct burners operate monthly and totalled every month for the 

previous 12 months.

4. Beginning the first full calendar year after demonstrating initial compliance in combined 

cycle mode, each CT shall be limited to operating 900 hours per calendar year (as an 

average across the four CTs) in simple cycle mode, except that:

a. During the first full calendar year, a one-time allocation of 3,480 hours per CT (as an 

average across the four CTs) shall be available for use by Permittee for events when 

the STG is unavailable (including, but not limited to, planned outages, forced outages, 

and derates);

b. If the one-time allocation is not fully used within the first full calendar year, the 

remainder may be carried over into the next calendar year; and

c. If the annual limit of 900 average hours per CT is not fully used in the first full 

calendar year (or any calendar year thereafter), the remainder may be added to the 

current year-end balance of the one-time allocation and carried over into the next 

calendar year, but never to exceed 3,480 average hours per CT.

5. Combined the CTs shall be limited to operating 3,000 hours per 12-month rolling period

when burning ULSD fuel oil, but no more than 48 hours per rolling 24-hour period. Of 

the 3,000 hours, no more than 1,500 hours may be in simple cycle mode. Permittee shall 

monitor and record the number of hours each CT operates on ULSD (as well as the 

corresponding operating mode) monthly and totalled every month for the previous 12 

months.
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 8

C. Auxiliary Equipment Emission and Operational Limits and Work Practices

1. The emergency generator shall be properly operated and maintained in accordance to 

manufacturer’s specifications.

2. The emergency generator shall be limited to operation of the engine for maintenance and 

testing purposes, except during an emergency. Annual hours of operation for an 

emergency stationary reciprocating internal combustion engine (as defined in 

40 CFR part 63, subpart ZZZZ) for maintenance and testing shall not exceed 100 hours 

per rolling 12-month period. Compliance with this condition shall be demonstrated in 

conjunction with Condition IX.E.1.

3. Circuit breakers shall be used as electrical interrupters in the event of a power surge. 

Circuit breakers shall be totally-enclosed, equipped with pressure gauges with internal set 

points, and include an alarm system that signals low pressure. Records of inspection shall 

be kept in accordance with Condition IX.F.

4. Piping components used for the transmission of natural gas to the duct burners of the 

HRSGs shall be inspected on a daily basis for potential leaks. Any detected leaks must be 

repaired immediately. Records of inspection, detected leaks, and repairs (including action 

taken and duration) shall be kept in accordance with Condition IX.F.

D. Continuous Monitoring of CO2 for CTs

1. Permittee shall install and certify monitoring systems for quantifying CO2 emissions from 

each CT in accordance with the applicable requirements of 40 CFR part 75. Consistent 

with 40 CFR § 75.4(b), all applicable certification tests shall be completed within 180 

calendar days after the date the unit commences commercial operation (as defined in 

40 CFR § 72.2).

2. Following initial certification, the CO2 continuous monitoring systems shall be quality 

assured in accordance with the applicable requirements of 40 CFR part 75.

3. The CO2 continuous monitoring systems shall be capable of producing hourly 

determinations of CO2 mass emissions in tons per hour (tons/hr).

4. In accordance with 40 CFR § 75.62, an initial monitoring plan shall be submitted 

identifying the methodology for which CO2 mass emissions will be continuously 

monitored. The initial monitoring plan shall be submitted no later than 21 days prior to 

the initial certification tests.

5. Permittee shall provide notifications as specified in 40 CFR § 75.61 for any event related 

to the continuous measurement of CO2.

6. Permittee shall measure and record, for each CT, the actual heat input (Btu) on an hourly 

basis in accordance with 40 CFR part 75.
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 9

7. Permittee shall measure and record, for each CT, the following on an hourly basis:

a. Gross energy output rate (MW);

b. CO2 mass emission rate (tons CO2/hr);

c. Heat input rate (MMBtu/hr);

d. Unit operating time, as described in 40 CFR § 75.57(b)(2);

e. The type of fuel (natural gas or ULSD fuel oil) burned;

8. Permittee shall calculate and record, for each CT, the following on a monthly basis:

a. Monthly average CO2 emission rate (lb CO2/MWh) calculated as the sum of each 

hourly CO2 mass emission rate times the unit operating time for the hour divided by 

the sum of the recorded energy output rates times the unit operating time for the hour 

for all hours of operation in each month. If more than one fuel is utilized in a month, a 

separate average CO2 emissions rate shall be calculated for each fuel.

b. Monthly average heat rate (Btu/kWh) calculated as the sum of each hourly heat input 

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

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

operation in each month times 1000. If more than one fuel is utilized in a month, a 

separate average heat input rate shall be calculated for each fuel.

9. Permittee shall calculate and record, for each CT, the following on an annual basis:

a. The 12-month rolling average CO2 emission rate (lb CO2/MWh), for each fuel 

combusted in the previous 12 months, shall be calculated as the sum of each monthly 

average value times the monthly energy output (MWh) divided by the sum of the 

energy output (MWh) generated during the 12-month period.

b. The 12-month rolling average heat rate (Btu/kWh), for each fuel combusted in the 

previous 12 months, shall be calculated as the sum of each monthly average heat rate

value times the monthly energy output (kWh) divided by the sum of the energy output

(kWh) generated during the 12-month period.

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

shall use the procedures set forth in 40 CFR parts 75 and 98 to determine resulting GHG 

emissions (as CO2e) based on the combination of measured CO2 emissions (from 

continuous monitoring system) and calculated CO2e of other GHG pollutants [as 

specified in Condition H: GLOBAL WARMING POTENTIAL (GWP)]. Permittee shall 

apportion the STG output (gross MW) based on the output (gross MW) of the individual 

CTs. Permittee shall keep adequate records of these GHG emission calculations 

according to requirements in Condition IX.F.1.
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 10

E. Monitoring and Compliance for Auxiliary Equipment

1. Permittee shall install and maintain an operational, non-resettable, elapsed-time meter for 

the emergency generator to be recorded monthly and totalled every month for the 

previous 12 months.

2. Permittee shall:

a. Continuously monitor and record circuit breaker pressure;

b. Visually inspect, in accordance with manufacturer’s standards, circuit breakers and 

components on a daily basis;

c. Provide periodic maintenance of the circuit breakers and components; and

d. Repair any leaks and replace equipment as needed.

F. Recordkeeping and Reporting 

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

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

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

system or device at the facility;

b. All records relating to performance tests and monitoring of auxiliary combustion 

equipment; and

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

develop, recorded in a permanent form suitable for inspection.

2. Permittee shall maintain continuous monitoring system records that include the 

following: the occurrence and duration of any startup, shutdown, shakedown, or 

malfunction, performance testing, evaluations, calibrations, checks, adjustments, 

maintenance, duration of any periods during which a continuous monitoring system or 

monitoring device is inoperative, and corresponding emission measurements.

3. Permittee shall maintain records of all source tests and monitoring and compliance 

information required by this permit.

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

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

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

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

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

shall include the following:
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 11

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

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

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

monitoring system was inoperative (monitor down-time), except for zero and span 

checks, and the nature of continuous monitoring system repairs or adjustments;

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

excess emissions occurred or when the continuous monitoring system has not been 

inoperative, repaired, or adjusted;

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

activities; and

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

on hours of operation.

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

the maximum emission limits set forth in this permit.

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

data are not obtained by the continuous monitoring system to validate the hour for CO2.

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

compliance monitoring shall be considered violations of the applicable emission limit for 

the purpose of this permit.

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

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

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

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

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

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

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

maintenance, reports, and/or records. These records shall be made available for review 

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

inspection.

G. Shakedown Periods

The combustion turbine and auxiliary equipment emission limits and requirements in 

Conditions IX.B and IX.C shall not apply during combustion shakedown periods. 

Shakedown is defined as the period beginning with initial startup and ending no later than 

initial performance testing, during which the Permittee conducts operational and 

contractual testing and tuning to ensure the safe, efficient and reliable operation of the 
PSD-EPA-R4014; TECO – Polk Power Station_DRAFT_09-23-2013 12

plant. The shakedown period shall not exceed 180 days. The requirements of Section III

of this permit shall apply at all times.

H. Global Warming Potential (GWP)

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

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

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

GHG Pollutant GWP Factor

CO2 1

CH4 21

N2O 310

SF6 23,900

X. AGENCY NOTIFICATIONS

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

submitted to:

Chief

Air & EPCRA Enforcement Branch

Air, Pesticides and Toxics Management Division

U.S. EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303

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

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

Name Email Phone

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

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

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