(j/IGott{er Associates 

November 30, 2012 

Mr. Gregg M. Worley 

Chief 

Air Permits Office 

United States Environmental Protection Agency, Region IV 

Atlanta Federal Center 

61 Forsyth Street 

Atlanta, Georgia 30303-8960 

10389556 

RE: NOTICE OF INCOMPLETENESS FOR PROPOSED FLORIDA SHADY HILLS GENERATING 

STATION PSD APPLICATION (EPA REGION 4 LETTER DATED OCTOBER 25, 2012) 

Dear Mr. Worley: 

This correspondence provides the additional information requested by the United States Environmental 

Protection Agency (EPA) concerning the Shady Hills Generating Station PSD Permit application. EFS 

Shady Hills LLC (Applicant or EFS Shady Hills) received the request for additional information on October 

31, 2012. Golder is submitting this information on behalf of the applicant, EFS Shady Hills LLC. The 

additional information is presented in the same sequence as in the EPA's letter, with a restatement of 

each comment followed by the response in boldface italics. It should be noted that the construction of the 

project may occur in a phased construction schedule depending on market conditions. 

1. The PSD application addresses the Project's applicability to the Endangered Species Act (ESA) 

and the National Historic Preservation Act (NHPA). In addition to these two Acts, all federal 

permits are potentially subject to the Magnuson-Stevens Fishery Conservation and Management 

Act (MSFCMA) and the Coastal Zone Management Act (CZMA). Please address the applicability 

of the MSFCMA and the CZMA to the Shady Hills Project and the status of any necessary 

assessments performed and/or communications with the appropriate federal agencies. 

Response: Golder Associates (Heather Ahrens) contacted NOAA's National Marine Fisheries 

Service (NMFS) regarding the Magnuson-Stevens Fisheries Act. Kyle Baker and Mark Sramek, 

NMFS Essential Fish Habitat (EFH) reviewed the project based on project information 

previously submitted to NMFS and have determined that there will be no impacts, or even 

remote impacts, to EFH. Mark Sramek stated that reference to Golder's phone conversation 

with NMFS, on 1118112, can be provided in our response to this request for additional 

information. Email documentation of Golder's conversation with Mark Sramek is provided in 

Attachment A. 

On 11/29/12 Golder submitted a request to the Florida Department of Environmental Protection 

(FDEP) for confirmation, that based on the characteristics and location of the Project, the 

Project is consistent with the Coastal Zone Management Act. A copy of the request is 

provided as Attachment A. 

2. Section 2.1.2.1 (page 11) of the application states "[i]t is the Project owner's understanding that 

for peaking plant, the offtaker(s) will not dedicate firm natural gas transportation to the Project, 

and instead will operate the units on natural gas when interruptible natural gas transportation 

service is available." Based on the discussion in the application, the use of an interruptible natural 

Golder Associates Inc. 

5100 W. Lemon Street, Suite 208 

Tampa, FL 33609 USA 

Tel: (813) 287-1717 Fax: (813) 287-1716 www.golder.com 

Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America 
Mr. Gregg Worley. 

EPA 2 

November 30, 2012 

10389556 

gas service is the reason why the Project includes 750 to 1 ,000 hours per year of fuel oil 

operation as backup for natural gas. The application indicates it would be redefining the source 

to have the Project use only natural gas as the fuel source. However, since your application 

considers the use of an interruptible natural gas source, we do not understand why use of 100% 

non-interruptible natural gas would fundamentally redefine the source. Accordingly, such an 

option should be included as part of the top-down best available control technology (BACT) 

analysis. The option of 100% non-interruptible natural gas may still be eliminated under one of 

the other steps of the BACT analysis. If the use of an interruptible natural gas source is 

fundamental to your project design, please provide additional information regarding the decision 

to use an interruptible natural gas source. 

Response: In order to deliver reliable electric service, simple cycle combustion turbine 

projects intended for peaking duty operation in Florida are typically developed with the ability 

to operate on natural gas (NG) as primary fuel and with fuel oil (FO) as back-up. As explained 

below, there are additional fixed operating costs incurred to procure firm NG transportation 

services (FT). In addition, provision for a back-up fuel is consistent with the recent BACT 

determination for York Plant Holding, LLC, a simple cycle project proposed for York County, 

Pennsylvania. 

The primary benefit of FO is that it enhances the reliability of the plant to generate electricity 

when needed to meet demand in the event of NG unavailability. The inclusion of FO-firing 

capability and on-site FO storage facilities in the project design also avoids the additional 

fixed operating costs associated with FT, which are incompatible with the expected low 

utilization of a peaking facility. Typically, FT is required to be procured based on potential 

maximum daily quantity and on a year-round basis (i.e., 8, 760 hours), while the PSD permit 

limits operations to 3,390 hours, thereby disproportionately increasing the cost burden of FT. 

Current tariff rates for FT are more than 2.5x higher than interruptible transportation (IT) 

service, which further diminishes the rationale for FT. Moreover, even with FT, there is still a 

possibility that NG might not be available due to unexpected interruption of the transportation 

service on the NG pipeline and/or the upstream NG commodity /infrastructure supply. 

However, EFS Shady Hills is providing consideration of 100% NG firing (based on utilization of 

FT, and ignoring any potential supply/transportation disruption) as an available control option. 

EFS Shady Hills has determined that using 100% NG firing is infeasible due to the mismatch 

between procurement requirements and permitted operations, and is not cost-effective, 

Updated Tables 2 and 2a, provided in Attachment B, to include the 100% NG operation 

scenario. The attached calculations demonstrate that 100% NG operation is not cost-effective 

for the Base Scenario (2 units installed), considering additional costs for firm gas 

transportation and reduced capital and O&M cost for eliminating FO operations, relative to the 

incremental C02e emissions reduction. For the Alternate Scenario in which only 1 unit is 

installed, the overall C02e emissions based on maximum potential to emit would increase if 

only NG were utilized since our PSD air permit requires a reduction in NG operating hours for 

each FO operating hour in excess of 500 hours per year. Thus, because the Alternate 

Scenario would result in both higher emissions and higher costs, NG only operation is not 

cost-effective. Tables 2 and 2a have also been updated to consider cost-effectiveness of the 

simple cycle technology alternatives based only on operating hours for consistency with the 

FDEP issued PSD permit for other criteria pollutants and since the contribution of startup/shut-down to C02e emissions is de minimus. 

3. Section 2.1.2.2 (page 11) the application discusses the energy efficiency of various GE 

combustion turbines and indicates the GE Frame 7 turbine is used as a surrogate for the 

performance of similar F class turbines from other vendors. Footnote 4 references a BACT 

analysis from the proposed Puget Sound Energy project in Washington which includes a 

~&\Golder \tYAssociates 
Mr. Gregg Worley. 

EPA 3 

November 30, 2012 

10389556 

comparison of GE turbines as well as a Siemens 5000F4 (F-class turbine of similar size) and a 

Pratt and Whitney FT-8. Based on the Puget Sound Energy application, we see that the GE 

7FA.05 is slightly more energy efficient than the F-Ciass turbines from the other vendors. 

However, the document is dated October 2011. Please verify that no new more efficient turbine 

models of similar size have become available since October 2011. 

Response: The Applicant has checked with their independent engineer and confirmed/verified 

that no new more efficient turbine models of similar size to the GE 7FA.05 have become 

available since October 2011. 

4. Section 2.1.5.1 (page 23) indicates the proposed GHG BACT emission limits for the turbines 

were derived assuming a 5% design margin and a 3% turbine performance degradation margin. 

Please provide documentation or an explanation on how these margins were derived, why they 

are appropriate for the GE 7FA.05 turbines proposed for this Project, and why turbine 

degradation is assumed even at the very beginning of its use. 

Response: A 5% margin has been included to account for design standards typical of 

construction contracts and equipment manufacturer's supply contracts, which contain 

provisions for minimum acceptable performance criteria. These include the ability for the 

contractor/supplier to "buy-down" performance by paying liquidated damages if performance 

(in this case, unit heat rate) does not meet the levels guaranteed in the contract. The typical 

minimum acceptance threshold for heat rate is up to 105% of the contractually guaranteed 

value, and thus we have used a 5% margin for this component of the compliance limit 

calculation. This limit is appropriate for the GE 7FA.05 turbines because it reflects market 

standard terms and conditions which are available in commercial contracts today. 

Turbine degradation is included in the compliance limit even at the very beginning of its use 

since the compliance limit is established as a single value over the lifetime of the unit(s). 

Turbine degradation occurs over time based on actual use of the unit(s), such as hours of 

operation, load changes, and start-up/shut-down cycles. Since the dispatch of the units will 

vary over time based on power market and system conditions, it is appropriate to include the 

degradation allowance in the compliance limits from the outset. The 3% value for turbine 

degradation margin reflects Applicant's experience with similar F class turbines. In addition, 

the Applicant's consideration of margins for CT design and performance degradation is 

consistent with the other BACT determinations including York Plant Holding, LLC, a simple 

cycle project proposed for York County, Pennsylvania. 

5. Section 2.1.5.1 (page 24) lists the BACT emission limits for startup and shutdown events as 21 

and 28 tons C02e per event while firing natural gas and fuel oil, respectively. Footnote 6 of Table 

3 in the Appendix indicates these were calculated using an estimate of 338 and 339 million 

thermal units (MMBtu)/event, respectively. So that the permit record will include the necessary 

calculations for the emissions from these events, please provide an explanation for how these 

emission factors were derived and an estimate of how long a startup and shutdown event will last, 

as well as the anticipated number of startup and shutdown events that will occur in a year. 

Response: Calculations of estimated emissions per start-up/shut-down cycle are provided 

below. The emissions estimates are based on estimated heat input per fuel per event and the 

C02e emission factors, lb C02e/MMBtu, developed in Table 1 of the application. 

~&\Golder \ZV'Associates 
Mr. Gregg Worley. 

EPA 

NATURAL GAS 

Component 

Startup (SU) fuel 

Shutdown (SD) fuel 

Total fuel per SU/SD event 

lHV to HHV conversion 

Fuel per SU/SD event 

lb C02e/mmBtu 

lb per SU/SD event 

Tons per SU/SD event 

Round up to nearest Ton per SU/SD event 

FUEL OIL 

Component 

Startup (SU) fuel 

Shutdown (SD) fuel 

Total fuel per SU/SD event 

lHV to HHV conversion 

Fuel per SU/SD event 

lb C02e/mmBtu 

lb per SU/SD event 

Tons per SU/SD event 

Round up to nearest Ton per SU/SD event 

4 

,.. 

160.5 

144.0 

304.5 

1.11 

338.0 

119 

40,226 

20.11 

21 

1n.6 

139.4 

317.0 

1.07 

339.1 

163 

55,228 

27.61 

28 

November 30, 2012 

10389556 

mmBtu (lHV) 

mmBtu (lHV) 

mmBtu {lHV) 

mmBtu (HHV) 

lb/mmBtu 

lb 

Tons 

Tons 

mmBtu (lHV) 

mmBtu (lHV) 

mmBtu (lHV) 

mmBtu (HHV) 

lb/mmBtu 

lb 

Tons 

Tons 

The estimated start-up time to minimum em1ss1on compliant load (for criteria pollutants 

regulated under FDEP's issued Final PSD air permit) is approximately 15 minutes, and the 

estimated shut-down time is 15 minutes from minimum emission compliant load to no load. It 

is our expectation that each CT unit could incur 250-300 start-up/shut-down cycles annually, 

but we will not constrain our potential off-takers' dispatch flexibility for the units by limiting 

the number of annual starts per CT. 

6. Section 2.2.1 and 2.3 (pages 28-30) discusses the BACT analysis for the emergency generator 

and fuel gas heater, respectively and provides calculations on how the emissions form each unit 

will be averaged to show compliance with the proposed BACT limits. For both of these emission 

units, BACT has been proposed as a ton per year limit on a "calendar year annual average"; 

AI\ Golder \ZIT' Associates 
Mr. Gregg Worley. 

EPA 5 

November 30, 2012 

10389556 

however, BACT applies at all times and EPA intends to include BACT limits on a 

rolling/consecutive 12-month or 365-day total basis. If necessary, please provide revised 

calculations based on the use of a rolling total basis. 

Additionally, page 29 of Section 2.3 indicates that fuel gas heater will operate 8,760 hours per 

year (100% of the time); however, the turbines associated with this Project will be limited (as 

proposed) to a maximum of 3,390 hours per year of operation. Please provide an explanation for 

why the new fuel gas heater would need to operate 8,760 hours per year. If necessary, please 

provide updated emission estimates and other relevant portions of the application based on the 

fuel gas heater operating fewer hours per year. 

Response: EFS Shady Hills accepts a compliance averaging period for both the emergency 

generator and fuel gas heater based on 12-month rolling/consecutive basis. 

With respect to p29, Section 2.3, the fuel heater must be able to operate 6, 780 hours/yr in 

order to accommodate the potential scenario of non-coincident operation of each CT for 3,390 

hours. An updated Table 4. Is provided in Attachment B. The resulting C02e emissions equal 

3,965 short tons per year. 

EFS Shady Hills appreciates EPA's consideration of this additional information. If you questions, please 

contact Mr. Roy Belden at (203) 357-6820 or me at (813) 287-1717 in Tampa. 

Sincerely, 

GOLDER ASSOCIATES INC. 

Scott Osbourn, PE 

Associate and Tampa Operations Manager 

cc: Roy Belden, EFS Shady Hills LLC. 

Attachments: Attachment A-FDEP CZMA Submittal 

Attachment B-Updated Application Tables 

DUd I/ 

Dave Larocca 

Senior Engineer 

~&\Golder ~Associates 
ATTACHMENT A 

Agency Correspondence 
Larocca, David 

From: Ahrens, Heather 

Sent: 

To: 

Friday, November 30, 2012 3:14PM 

Mark.Sramek@noaa.gov 

Cc: Larocca, David 

Subject: Shady Hills Generating Station ESA Consultation 

Mark, 

On October 25, 2012, the EPA sent a request for additional information for the referenced project regarding the 

applicability of the Magnuson-Stevens Fishery Conservation and Management Act (see excerpt below): 

The PSD application addresses the Project's applicability to the Endangered Species Act (ESA) and the National 

Historic Preservation Act (NHPA). In addition to these two Acts, all federal permits are potentially subject to the 

Magnuson-Stevens Fishery Conservation and Management Act (MSFCMA) and the Coastal Zone Management 

Act (CZMA). Please address the applicability of the MSFCMA and the CZMA to the Shady Hills Project and the 

status of any necessary assessments performed and/or communications with the appropriate federal agencies. 

Golder's position is that the MSFCMA does not apply to the Shady Hills Project since the Project is located inland in 

Pasco County, Florida, and fisheries habitat/resources are not present on site. Per our telephone conversation on 

November 8, 2012, NMFS agrees that the MSFCMA is not applicable to this Project. Furthermore based on the location 

of the Project, NMFS does not anticipate any impacts, even remotely, to essential fish habitat. 

If you have any questions or concerns, please contact me at (813) 769-5307 or (813) 407-8846 to discuss further. 

Regards, 

Heather Todd Ahrens 1 Senior Ecologist 1 Golder Associates Inc. 

5100 West Lemon Street, Suite 208, Tampa, Florida, USA 33609 

T: +1 (813) 287-17171 D: +1 (813) 769-53071 F: +1 (813) 287-17161 C: +1 (813) 407-88461 E: 

Heather Ahrens@golder.com 1 www.golder.com 

Plc;;~.c rons:dr-1 lht: E nvironn1t ,,t bpfon~ printitt~) this em<iiL 

From: Ahrens, Heather 

Sent: Thursday, March 29, 2012 10:42 AM 

To: Kyle.Baker@noaa.gov 

Cc: Osbourn, Scott; Larocca, David 

Subject: Shady Hills Generating Station ESA Consultation 

Kyle, 

Thank you for taking time out of your busy schedule to discuss the referenced project with me today as well as during 

our original conversation on October 7, 2011. My understanding from our conversations is that the NMFS would make a 

no effect determination because the site is located inland in Pasco County, Florida, and therefore, species regulated by 

1 
NMFS for this area (i.e., gulf sturgeon and sea turtles) would not be present on site. It is also my understanding that the 

NMFS does not send no effect determination correspondence. 

Please do not hesitate to contact me if you have any questions or concerns regarding this matter. 

Regards, 

Heather Todd Ahrens 1 Senior Ecologist 1 Golder Associates Inc. 

5100 West Lemon Street, Suite 208, Tampa, Florida, USA 33609 

T: +1 (813) 287-17171 D: +1 (813) 769-53071 F: +1 (813) 287-17161 C: +1 (813) 407-88461 E: 

Heather Ahrens@golder.com 1 www.golder.com 

' ~·; ' ,' I ' 

' , . r~ \ :. t • , • -; ~ • ~ f r.) r : 

2 
Larocca, David 

From: 

Sent: 

To: 

Cc: 

Subject: 

Attachments: 

Hello Lauren, 

Hartman, Kelly 

Thursday, November 29, 2012 9:19 AM 

Milligan, Lauren (Lauren.Milligan@dep.state.fl.us) 

Larocca, David 

Shady Hills Generating Station Expansion Project 

103-89556C001 Figure 1 SITE LOCATION.pdf; 103-89556C002 Figure 2 AERIAL.pdf 

A subsidiary of Shady Hills, the Shady Hills Power Company, LLC, owns and operates the Shady Hills Generating Station 

located at 14240 Merchant Energy Way, Shady Hills, Pasco County, Florida. Shady Hills is proposing to expand the Shady 

Hills Generating Station with the addition of two nominal 218-megawatt (MW) simple cycle combustion turbine-electric 

generators and associated ancillary equipment (Project.) The proposed expansion is a major modification to the existing 

facility and subject to Prevention of Significant Deterioration (PSD) for specific air emissions. The Florida Department of 

Environmental Protection has issued a final air construction permit (Air Permit No. 1010373-012-AC PSD-FL-402A) for 

the project for all applicable air pollutants except greenhouse gas (GHG}. The Shady Hills Generating Station and Project 

are located in unincorporated Pasco County, Florida within Section 25, Township 24S, and Range 17E (Figures 1 and 2}. 

The Shady Hills property is approximately 30 acres. 

EPA Region IV is the permitting authority for the GHG-portion of the expansion project under a Federal Implementation Plan 

(FIP) that became effective on December 30, 2010. Federal law requires that a federal agency's actions be in compliance 

with the Coastal Zone Management Act. 

Golder respectfully requests that you review the project and confirm that, based on the characteristics and location of the 

Project, the Project is consistent with the Coastal Zone Management Act. 

If you have any questions, please feel free to contact me. 

Thank you, 

Kelly L. Hartman 1 Environmental/Land Use Planner 1 Golder Associates Inc. 

5100 W. Lemon Street, Suite 208, Tampa, Florida, USA 33609 

T: (813) 287-17171 D: (813) 769-5311 I C: (352) 514-47601 F: (813) 287-17161 E: khartman@golder.coml 

Work Safe, Home Safe 

This e-mail transmission is confidential and may contain proprietary information for the express 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 are susceptible to unauthorized modification, deterioration, 

and incompatibility. Accordingly, the electronic media version of any work product may not be relied upon. 

~Please consider the environment before printing this email 

1 
"' 

CJ APPROXIMATE SITE 

BOUNDARY 

APPROXIMATE EXPANSION 

PROJECT AREA 

=TOLL ROAD 

I =US ROAD , 

"0 

.. 

.r:: 

(/) 

w 

(!) 

ill 

"' "' "' "' 0 

6 

0 

"' (/) 

>-

0 

w 

0 

"' 

~ 

-STATE ROAD 

-- COUNTY ROAD 

!::._'. _j COUNTY BOUNDARY 

REFERENCES 

1 APPROXIMATE PROJECT BOUNDARY GOLDER ASSOCIATES INC 2011 

2 ROADS FLORIDA DEPARTMENT OF TRANSPORTATION, 2011 

3 COUNTY BOUNDARIES FLORIDA GEOGRAPHIC DATA LIBRARY, 2008 

4 USGS TOPOGRAPHIC MAP. NATIONAL GEOGRAPHIC SOCIETY, 2010 

SHADY HILLS GENERATING STATION 

TITLE 

SITE LOCATION- TOPOGRAPHIC 
1ii 

~ 

'§ 

0 

~ 0 

·;;; 

·;; 

Q) 

"' ~ 

I 

,., 

"' "' s:; 

(/) 

w 

<.9 

~ 

"' 0) 

I I 

SHADY HILLS GENERATING STATION 

"' SITE LOCATION -AERIAL "' 0 

6 

0 REFERENCES 0 

~ 2 

1 APPROXIMATE 

AERIAL ARC GIS 

PROJECT 

ONLINELOCATION BING MAPS 

GOLDER 

AERIAL, 

ASSOCIATES 

MICROSOFT 

INC 

CORPORATION 

, 2011 

AND ITS DATA 

~-Golder O SUPPLIERS. 2010 

"' Associates 

9, Tampa, Florida 

~~------------------------------------------------~------------------~----~--~----~--------------~ 
ATTACHMENT B 

Updated Applications Tables 
Table 2. Shady Hills Expansion: Cost Effectiveness Analysis tor Alternative Simple Cycle Generation Technologies 

Base scenario - Both units Installed 

Plant Total OUtput (MW) 425 

Number of Turbines (Unit) 2 

Capacity Factor (%) 38 7"/o 

Fuel Operating Hoots (Hrurs) 3,390 

Percentage ofoperatM:In by fuel --NG (%) 85% 

-- FO (%) 15% 

Annual operating hours --NG (Hours/year) 2,890 

--FO (Hrurs/year} 500 

Net Plant Heat Rate (lHV} --NG (Btu/kWh} 8,928 

-- FO (Btu/kWh} 9,708 

HHV/LHV CcwwersM)n --NG 111 

--FO 107 

Net Plant Heat Rate (HHV) --NG (Btu/kWh} 9,910 

--FO (Btu/kWh) 10,388 

500 

Fuel Pnce --NG ($/MMBtu) 

-- FO ($/MMBtu) 20 

C02e (fuel HHV basis. incl C02. N20 and CH4) --NG (lb:MMBtu} 119 

--FO (lb'MMBtul 163 

;;,t.;;;""""""'""'"'•'"-m 

! 617 

I 

Capital Cost ($/kW) 

F1~ed Charge Rate (%) 11.0% 

18.2 

Fixed Operation & Mwntenance costs (F1~ed O&M) ($/kW-yr) 

Vari~e Operation & Maintenance costs (Vanable O&M) ($/MWh) 7.44 

Energy Produced Total (MWh/yr) 1,44(1,801 

-- NG 1,228,301 

-- FO 212.500 

Fuel Consumption Total (MMBtu!yr) 14,379,913 

-· NG 12,172,463 

--FO 2,207,450 

C02e Emission Total (ShortTons/yr) 904,094 

--NG 724,353 

-· FO 179.742 

Emission Dttterence to 7FA.05 (ShortTons/yr) 

Capital Recovery I $/kW-yr !I: 6771 1$ 

Fi~edO&M $/kW-r 182 11 $ 

Total fixed revenue req't OlkW·Y' 

II$ 85.911. Fuel- NG $/MWh 49.6 .$ 

Fuel- FO $/MWh r 198.2: I$ 

Fuel- Weigl1ted $/MWh 

I ! ":II: Fuei-Sta<tup $/MWh 

VariableO&M $/MWh 74 $ 

Total variable revenue req'1 $/MWh I ! • 78: II$ Capital Recovery $MM!yr 1ll 28.81 $ R~edO&M $MM/yr 7.7 .$ 

Fuel $MM/yr II$ 103.0 1.$ VariableO&M $MM.vr ''$ 10.7' .$ 

Total SMM/yr II' 150.2: ! s 

Ail-In cost of electricity $;MWh ::s 104311$ 

Differences v 7FA 05 Option $MM/yr II I$ $/Shari Ton C02e I$ 

• NG =natural gas, FO =ultra low sulli.X fuel o1I.LHV =lower heat1ng value; HHV =higher heatmg value 

• C02e · Includes C02. N20, and CH4 and is based on 40 CFR Part 75 and Part 98 factors. 

• S•gma Energy estimate 1s based on 2011 ovem>ght dolars. Escalated to 2015 dollars us•ng 2% Annuallnflabon Rate 

• 10% Contmgency built into the capital cost estimate proVIded by S~gma for S1mple Cycle units 

• FOM and VOM costs are escalate at 2% amual rate. Inputs 1n this table IS a levellzed rate over 20 years horiZon. 

• Output and heat rate values above are net of plant auxiliary loads and Incorporate a degradation allowance over the 20 year honzon. 

• F1~ed charge rate used above for evaluation consistent wrth long-term Investment considerations 

Source EFS 2012. S1gma2012 Revis>on 11130112 

425 425 

10 

38.7% 38.7% 

3,390 3.390 

85% 85% 

15% 15% 

2,890 2,890 

500 500 

8,312 i 7.971 

8,489 ' 8.061 

111 1.11 

107 

i 

1.07 

9,226 8,848 

9.083 ! 8,625 

5.00 5.00 

20 20 

119 119 

163 163 

1129 979 

i 

110% 

i 

11.0% 

288 

i 

258 

7.11 

i 

578 

1,44(1,801 1,440,801 

1,228,301 1,228,301 

212,500 212,500 

13,262,443 12,700,820 

11,332,305 10.868.007 

1,930.138 1.832,813 

831,519 795,965 

674,357 646,728 

157,161 149.237 

-72,576 -108,130 

1240 I$ 

288 '$ 

"'·~I i. 461 ! $ 184.5 I '$ 

66.511$ 

- I$ 

7.1 i$ 

73.7 '$ 

52.7 $ 12.2 $ 95.9 

10.2 ; l 171.0 ! • 118.7 '$ 

20 ,I i $ 286.81 '$ 

107.5 $ 258 $ 

133.3 

44.2 $ 177.0 $ 63.8 $ 

$ 

58 $ 

69.6 $ 

45.7 $ 

11.0 $ 

91.9 $ 

8.3 $ 156.9 

108.9 $ 

6.7 $ 61.9 $ 

2 ~ 7FA05 

100o NG Operations Comments to ~~~~r~G Operat•ons 

425 

2 

38 7% 

3.390 

100% 

0% 

3.390 

() 

8,928 

1.11 

1.07 

9,910 

439 

119 

582 

11.0% 

1548 

707 

1,440,801 

1,440,801 

14,278,338 

14,278,338 

() 

849,668 

849,668 

() 

·54,426 

~ 

63 9: 

154.8 1 

218.7 

43.5 

198.2 

43.5 

7.1 

50.6 

271 

658 

627 

102 

165.8 

115.1 

156 

286.2 

100% NG operations 

100% NG operations 

1 00% NG operations 

Reduce delivered fuel price by FGT's 

CUI"Tent IT$-1 tarlft of $0.61071mm81u 

for tntetTuptible Transportation 

100% NG operations 

100% NG operations 

Reduce capttal cost by S15MM to 

remove FQ-flring cepabllty for 2 units 

(CTs, BOP, storage} 

Reduce Fixed O&M by 2.5% tor 100% 

NG operations; add Firm 

Transportation tarlft charges based 

on FGT"s FTS-3 recourse rate of 

$1.5791/mmBtu for me~ dally quantity 

on 365-day/yr besls, e~pressed one 

$1kW-yrbasis 

Reduce Variable O&M by 5%for 100% 

NGoperatlons 
Table 2a. Shady Hills Expansion: Cost Effectiveness Analysis for Alternative Simple Cycle Generation Technologies 

Alternate scenario- Only 1 unit Installed 

Capacity Factor 

Fuel Operating Hours 

Percentage of opera:tion by fuel 

Annual operating hours 

Net Plant Heat Rate (LHV) 

HHV/LHV Cooversoo 

Net Plant Heat Rate (HHV) 

Fuel Price 

C02e (fuel HHV basiS. 1ncl C02. N20 at"'d CH4l 

Capital Cost 

Fixed Charge Rate 

F1xed Operatlon & Maintenance costs (Fixed O&M} 

Variable Operallon & Mrunlenance costs (Variable O&M) 

Fuel Consumption 

C02e Emission 

Emission Dtffereoce to 7FA.OS 

Capital Rec011ery 

FixedO&M 

Total fixed revenue req'1 

Fuel- NG 

Fuel- FO 

Fuel- Weighted 

Fuel-Startup 

VariableO&M 

otal variable revenue req'1 

Capital Rec011ery 

FixedO&M 

Fuet 

VariableO&M 

Total 

All-lncostotelectrk:Hy 

Oifferencesv. 7FA.050ption 

--NG 

--FO 

--NG 

.. FO 

--NG 

-· FO 

--NG 

--FO 

--NG 

--FO 

--NG 

--FO 

-- NG 

--FO 

Total 

··NG 

--FO 

Total 

--NG 

--FO 

. 

(%) 

(Hours) 

(%) 

(%) 

(Hours/year) 

(Hours/year) 

(Btu/kWh) 

(Btu/kWh) 

(Btu/kWh} 

(Btu/kWh} 

($/MMBtu) 

($/MMBtu) 

(lb/MMBtu) 

(lbiMMBtu} 

($..1<.W) 

(%) 

($/kW-yr) 

($/MWh} 

(MMBtu/yr) 

(ShortTons/yr} 

(ShortTons!yr) 

$..'kW-yr l!s $..'kW-r : $ 

$/kW-yr is $1MWh Is $1MWh Is $/MWh 'I$ 

$1MWh 

$/MWh i I~ $/MWh Is $MM!yr Is $MM/yr IS $MM!yr !$ $MMyr 

5MM/yr 

! I' $/MWh :I• $MM/yr i $/Short Ton C02e 

• NG =natural gas; FO =ultra low sulfur fuel 011; LHV =lower heat1ng value; HHV = htgher healing value 

• C02e- 1ncludes C02, N20, and CH4 and IS based on 40 CFR Part 75 and Part 98 factors. 

27.3% 

2,390 

69% 

31% 

1,640 

750 

8,928 

9,708 

1.11 

1.07 

9,910 

10,388 

500 

20 

119 

163 

617 

11.0% 

182 

744 

5,109,223 

3,453.635 

1,655,588 

340,322 

205,517 

134,805 

• S~gma Energy est1mate IS based on 2011 ovemiQhl dolars. Escalated to 2015 dollars using 2% Annuallnflat10n Rate 

• 10% Cont1ngency bUilt 1nto the caprtal cost est1mate pro111ded by S~gma for S1mple Cycle units 

• FOM and VOM costs are escalate at 2'% annual rate. Inputs In this table IS a levehzed rate over 20 years honzon. 

677 !$ 182 's 85.9 s 49.6 i. ~~~-~ I~ 

~4 i ~ 103.6 Is 144 

3.9 i: 489 I• 3.8 ,,70.9 I' 139.6 I• 

'$ Is 

• Output and heat rate values above are net of plant aux1hary loads and mcorporate a degradation allowance over the 20 year honzon 

• F1xed charge rate used above lor evaluation consistent With long-term Investment considerallons 

Source EFS 2012. Stgma 2012 ReviSion t t 1

30/12 

27.3% 

2.390 

69% 

31% 

1,640 

750 

8,312 

8,489 

111 

107 

9.226 

9,083 

500 

20 

119 

163 

1129 

11.0% 

28.8 

711 

4,662,864 

3,215,261 

1,447.603 

309,202 

191,332 

117,870 

-31,120 

123.~! ! $ 288 I $ 

152.711 s 

:!.~ i i ~ 8:.6 i i ~ 

?til$ 

96.71 ! s 

"'II' 61 I I$ 

4~-~ I ~~ 

81.511' 

160.6! Is 

~~-~!I: 

273% 

2,390 

69% 

31% 

1,640 

750 

7,971 

8,061 

1.11 

1.07 

8,848 

8,625 

5.00 

20 

119 

163 

979 

11.0% 

25.8 

578 

4,458,137 

3.083,528 

1.374,609 

295,420 

183,493 

111,927 

-44,903 

107.5 

258 

133.2 

442 

177.0 

859 

58 

91.7 

22.8 

55 

436 

2.9 

74.9 

147.4 

4.0 

887 

2 x 7FA05 

toooo NG OperatiOns Comments to ~~0n"ar~G Operat ons 

213 

387% 

3,390 

100% 

0% 

3,390 

0 

1.11 

1.07 

439 

582 

11,0% 

154.8 

7.07 

7,139,169 

7,139.169 

0 

424,834 

424.834 

0 

84,512 

NA-Em1ssion Increase 

NA - Emission Increase 

NA Emission Increase 

NA Em1ssiontncrease 

NA Emtsstonlncrease 

10(l'>;:.NGoperatlons 

100%NGoperatlons 

100% NG operations 

Reduce delivered fuel price by FGT's 

current IT5-1 tartff of $0.6107/mmBtu 

lor Interruptible Transportation 

100% NG operations 

100% NG operations 

Reduce capital cost by $7.5MM to 

remove FQ-flrlng capability lor 1 unit 

(CTs, BOP, st01'"1tQe) 

Reduce Axed O&M by 2.5% for 100% 

NG operations; add Firm 

Transportation tariff charges based 

on FGT's FTS-3 recourse rate of 

$1.5791/mmBtu for max dally quantity 

on 365-daylyr basis, expressed on a 

$/kW-yrbasis 

Reduce Variable O&M by 5% for 100% 

NGoperatlons 

100% NBtural Gas Case Results in 

higher C02e emissions as a result 

higher capactly factor allowed 
TABLE 4. Shady Hills Expansion: GHG Emissions for the Proposed Emergency Generator and Fuel Gas Heater 

C02 Emissions (a) 

Emission 

Heat Input Operation Annual Heat Input Factor Annual Emissions 

Unit (MMBtu/hr) (Hr/yr) (MMBtu/yr) (lb/MMBtu) (Shorttons/yr) 

Emergency Generator 9.73 500 4,864 163.0 396 

Fuel Gas Heater 10 6780 67,800 116.9 3961 

(a) Table C-2, Subpart C, 40 CFR Part 98. Emission factors in kg/MMBtu were converted to lb/MMBtu by multiplying by 2.204. 

(b) C02e = C02 + (21 x CH4) + (310 x N20) 

Source: Golder, 2012; Revision 11/30/12 

N20 Emissions (a) 

Emission 

Factor Annual Emissions 

(lb/MMBtu) (Short tons/yr) 

1.32E-03 3.22E-03 

2.20E-04 7.47E-03 

CH4 Emissions (a) 

Emission 

Factor Annual Emiss

(lb/MMBtu) (Short tons/

6.6E-03 1.61 E-02 

2.2E-03 7.47E-02