TECHNICAL EVALUATION AND PRELIMINARY DETERMINATION

I. APPLICATION INFORMATION
A. Applicant Name and Address
Orlando Utilities Commission (OUC)
500 South Orange Avenue
Post Office Box 3193
Orlando, Florida 32802
Authorized Representative: Denise Stalls, Vice President Environmental Affairs
B. Processing Schedule
December 26, 2006: Department issued Prevention of Significant Deterioration (PSD) Permit
PSD-FL-373 to construct an integrated coal gasification and combined cycle
(IGCC) unit at the OUC Curtis H. Stanton Energy Center (Stanton Unit B).
November 13, 2007: Southern Power and OUC mutually agreed to terminate the IGCC Project.
March 6, 2008: Department received a complete PSD application to construct a natural gas-
fueled combined cycle (NGCC) unit in lieu of the IGCC unit.
March 25, 2008: The Intent to Issue PSD Permit was distributed.
C. Facility Location
The OUC Curtis H. Stanton Energy Center (the Stanton Plant) is located in Orange County,
Southeast of Orlando and North of Highway 528 at 5100 South Alafaya Trail. The OUC Stanton
Plant presently consists of two fossil fuel-fired steam electrical generating units and a combined
cycle unit. Fossil fuel-fired steam electric generating Units 1 and 2 (468 MW each) began
operation in 1987 and 1996 while Combined Cycle Unit A (640 MW) began operation in 2003.
The site is located 144 km southeast from the Chassahowitzka National Wildlife Area; the nearest
Federal Prevention of Significant Deterioration (PSD) Class I Area. The UTM coordinates for this
site are 483.6 km East and 3151.1 North. The location of the OUC Stanton Energy Center is
shown in Figure 1.

Figure 1. Project Location near Orlando. Figure 2. Aerial View of the Stanton Plant.

D. STANDARD INDUSTRIAL CLASSIFICATION CODES (SIC)

Industry Group No. 49 Electric, Gas, and Sanitary Services
Industry No. 4911 Electric Services

OUC Curtis H. Stanton Energy Center DEP File No. 0950137-020-AC

Combined Cycle Project – Unit B Draft Permit No. PSD-FL-373A
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E. Regulatory Classifications
40 CFR 60, Subpart KKKK. The proposed project is subject to 40 Code of Federal Regulations
(CFR) 60, Subpart KKKK - Standards of Performance for Stationary Combustion Turbines that
Commence Construction after February 18, 2005. This rule also covers duct burners that are
incorporated into combined cycle projects.
40 CFR 60, Subpart Kb. A proposed distillate fuel oil tank has a capacity greater than or equal to
40,000 gallons (151 cubic meters) and is storing a liquid with a maximum true vapor pressure less
than 3.5 kPa, and is therefore not subject to Subpart Kb.
40 CFR 63, Subpart YYYY. The existing facility is a major source of hazardous air pollutants
(HAP). The new unit is potentially subject to 40 CFR63, Subpart YYYY - National Emission
Standards for Hazardous Air Pollutants for Stationary Combustion Turbines. The applicability of
this rule has been stayed for lean premix and diffusion flame gas-fired combustion turbines such as
planned for this project.
Title IV, Clean Air Act, Acid Rain Provisions. The facility operates units subject to the Acid Rain
provisions of the Clean Air Act.
Title V, Clean Air Act, Permits. The facility is a Title V or “Major Source” of air pollution
because the potential emissions of at least one regulated pollutant exceed 100 tons per year (TPY)
or because it is a Major Source of HAP. Regulated pollutants include pollutants such as carbon
monoxide (CO), nitrogen oxides (NOX), particulate matter (PM/PM10/PM2.5), sulfur dioxide (SO2),
volatile organic compounds (VOC) and sulfuric acid mist (SAM).
Prevention of Significant Deterioration (PSD). The facility is located in an area that is designated
as “attainment”, “maintenance”, or “unclassifiable” for each pollutant subject to a National
Ambient Air Quality Standard. The facility is classified as a “Fossil fuel-fired steam electric plants
of more than 250 million British thermal units per hour heat input”, which is one of the facility
categories with the PSD applicability threshold of 100 tons per year (TPY). Potential emissions of
at least one regulated pollutant exceed 100 TPY per year, therefore the facility is classified as a
“Major Stationary Source” with respect to Rule 62-212.400 Florida Administrative Code (F.A.C.).
Siting. The facility was originally certified pursuant to the power plant siting provisions of Chapter
62-17, F.A.C. The certification was modified to include the IGCC project.
II. PROPOSED PROJECT SUMMARY
A. Project Description
Instead of the planned IGCC project, the applicant proposes to construct a “one-on-one” F-Class
NGCC unit (Stanton Unit B) and associated auxiliary equipment. Unit B will consist of: one
nominal 150 megawatts (MW) General Electric 7241 FA combustion turbine-electrical generator
(CTG); a supplementary fired heat recovery steam generator (HRSG) with natural gas fueled duct
burners; and a nominal 150 MW steam turbine generator (STG) for an overall nominal rating of
300 MW. The project includes highly automated controls, described as the GE Mark VI Gas
Turbine Control System to fulfill all of the gas turbine control requirements.
According to OUC the project is a revision of the previously permitted IGCC. The NGCC version
of the project will allow firing of natural gas as the primary fuel, with ultralow sulfur diesel
(ULSD) fuel oil serving as a backup fuel, while removing the coal handling, gasification and
synthetic gas cleanup components.

OUC Curtis H. Stanton Energy Center DEP File No. 0950137-020-AC

Combined Cycle Project – Unit B Draft Permit No. PSD-FL-373A
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Auxiliary equipment includes the following: a nominal 1,000,000 gallon tank for the storage of
ultralow sulfur diesel (ULSD) fuel oil; a six-cell mechanical draft cooling tower equipped with
drift eliminators; and a 205-foot exhaust stack.
• Fuel: Stanton Unit B will use natural gas as the primary fuel for up to 8760 hours per year, and
ULSD fuel oil (0.0015% Sulfur) as a backup fuel. The applicant requests operation with ULSD
fuel oil up to 1000 hours per year.
• Generating Capacity: The combustion turbine has a nominal generating capacity of 150 MW.
The duct-fired HRSG provides steam to the steam turbine electrical generator, which has a
nominal capacity of 150 MW. The total nominal generating capacity of Stanton Unit B is 300
MW.
• Controls: CO and PM/PM10/PM2.5 will be minimized by the efficient combustion of natural gas
and ULSD fuel oil at high temperatures. Emissions of SAM and SO2 will be minimized by
firing natural gas and ULSD fuel oil. NOX emissions will be reduced with dry low-NOX (DLN)
combustion technology for gas firing and water injection for oil firing. In combination with
these NOX controls, a selective catalytic reduction (SCR) system further reduces NOX
emissions during combined cycle operation.
• Continuous Emissions Monitoring Systems (CEMS): The combustion turbine is required to
continuously monitor NOX emissions in accordance with the acid rain provisions. The same
CEMS as well as CO CEMS are employed for demonstration of continuous compliance with
certain Best Available Control Technology (BACT) determinations. Flue gas oxygen content
or carbon dioxide content will be monitored as a diluent gas.
• Stack Parameters: The heat recovery steam generator has a combined cycle stack (HRSG
stack) that is 205 feet tall with a nominal exit diameter of 20 feet (+1 foot). The following table
summarizes the exhaust characteristics at 100 % load and with duct burners on.
Table 1 lists the nominal characteristics of Stanton Unit B when referenced to 20 degrees
Fahrenheit (°F). This temperature occurs very infrequently in Central Florida, but reflects the
conditions of maximum air density and therefore greatest throughput, fuel consumption and
combustion turbine (CT) power production.
Table 1. Exhaust Characteristics of Unit 1 at 100% Load and 20 °F

Heat Input of CT Compressor Turbine Exhaust Stack Exit Stack Flow

Fuel
(HHV)* Inlet Temp. Temp., °F Temp., °F ACFM

Gas 1925 mmBtu/hour 20° F 1,073° F 227 °F 1,031,061

ULSD F.O. 2100 mmBtu/hour 20° F 1,121° F 262 °F 1,239,934
* Duct burners are used at higher temperatures and account for an additional 450 mmBtu of heat input.
B. Process Description
A gas turbine is an internal combustion engine that operates with rotary rather than reciprocating
motion. Ambient air is drawn into the 18-stage compressor of the GE 7241FA CTG (also called a
7FA) where it is compressed by a pressure ratio of about 15 times atmospheric pressure. Figure 3
is a photograph from the GE website of a "7FA on the half-shell" with the compressor section in
the foregrounds and the rotor (expansion) section in the rear.

OUC Curtis H. Stanton Energy Center DEP File No. 0950137-020-AC

Combined Cycle Project – Unit B Draft Permit No. PSD-FL-373A
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The compressed air is then directed to the combustor section, where fuel is introduced, ignited, and
burned. The combustion section consists of 14 separate can-annular combustors. A preassembled
7FA is shown in Figure 4 prior to coupling with the rest of the components.

Figure 3. A GE 7FA on a half-shell. Figure 4. Preassembled GE 7FA ready for shipping.

Flame temperatures in a typical combustor section can reach 3600 degrees Fahrenheit (°F). Units
such as the 7FA operate at lower flame temperatures, which minimize NOX formation. The hot
combustion gases are then diluted with additional cool air and directed to the turbine -section at
temperatures of approximately 2500 °F. Energy is recovered in the turbine section in the form of
shaft horsepower, of which typically more than 50 percent (%) is required to drive the internal
compressor section. The balance of recovered shaft energy is available to drive the external load
unit such as an electrical generator. Turbine exhaust gas contains more than 12% oxygen (O2) at a
temperature greater than 1000 °F and is available for additional energy recovery.
There are three basic operating cycles for gas turbines. These are simple, regenerative and
combined cycles. In the Stanton Unit B project, the unit will operate primarily in combined cycle
mode, meaning that the gas turbine drives an electric generator while the exhausted gases are used
to raise steam in a heat recovery steam generator (HRSG). The key components of a combined
cycle unit (without duct firing) are shown in the figure below. The steam is then fed to a separate
steam turbine, which also drives an electrical generator producing additional electrical power. In
combined cycle mode, the thermal efficiency of the 7FA exceeds 50% on a higher heating value
(HHV) basis.

Figure 5. Components Combined Cycle Unit

OUC Curtis H. Stanton Energy Center DEP File No. 0950137-020-AC

Combined Cycle Project – Unit B Draft Permit No. PSD-FL-373A
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