Florida Power & Light (FPL) has worked out a deal with the Florida Department of Environmental Protection to delay compliance with new NO2 emissions standards at 48 peaking turbines at three plants until the end of 2016, at which point replacement combustion turbines will have been built.
NO2 is formed from vehicle, power plant, and other industrial emissions. A new 1-hour NO2 Standard has a particular impact on the operation of electric utilities’ peaking units, which operate only at certain times to serve peak demands and do not operate continuously throughout the entire year, FPL explained in a June 28 filing at the Florida Public Service Commission. This is because the NO2 emissions measured over a single hour from a peaking unit may be relatively high, while the annual average for that unit is much lower, taking into account that the unit is not operating during most hours.
FPL has 48 peaking gas turbines (GTs) in total among three generation sites: the Plant Fort Lauderdale (PFL), Plant Port Everglades (PPE) and Plant Fort Myers (PFM). This particular combustion technology was installed at these plants in the 1960s and entered into commercial operation in the early 1970s.
FPL said it became aware that the GT combustion technology – with its higher NOx emissions and short stacks that are close to property boundaries – might not adequately facilitate off-site dispersion of stack emissions to concentrations below the new 1-hour NO2 Standard. FPL therefore performed an analysis of the GTs at these three plants, including stack testing, dispersion modeling, and other data analysis. That analysis, completed in early 2013, confirms that emissions from the GTs that are allowed under applicable permits nonetheless will cause or contribute to ambient concentrations in excess of the 1-hour NO2 Standard at the property boundary.
If FPL does not address the NO2 emission compliance issue for these GTs, it could be faced with a mandatory shutdown of these valuable generation resources by the Florida DEP, the utility noted.
FPL has agreed to a plan with the DEP that allows it to continue operating the GTs until the end of 2016, in exchange for FPL’s commitment to meet the 1-hour NO2 Standard at the plants’ property boundaries by that time. FPL investigated a series of compliance alternatives to determine how to meet the standard at the least cost to FPL’s customers.
FPL identified three potential approaches:
- retrofitting the GTs with emission control equipment that would reduce NO2 enough to meet the standard;
- retiring all of the GTs and then accelerating the next planned generating unit (a combined cycle (CC) unit) as needed to maintain system reliability; and
- changing out the plants’ GT combustion technology in favor of highly efficient combustion turbines (CTs) that have much lower NO2 emissions and also meet system reliability requirements.
The third alternative is the most cost-effective solution. It will allow FPL to comply with the standard and maintain the required reliability at a cost to customers that is $56m lower on a cumulative present value of revenue requirements (CPVRR) basis than the next-best alternative.
Project would cut the utility’s capacity by about 300 MW
“The existing GTs at the PFL, PPE, and PFM plants represent a small but important portion of the power generation at these sites, which also have or will have large CC units that serve FPL’s base load continuously throughout the year,” FPL said. “These other combustion technologies at the sites comply with the new 1-hour NO2 Standard and thus do not have the same environmental compliance issue as the GTs. The modern CTs that FPL would operate at these sites will have less peaking capacity in the aggregate than the GTs and accordingly will not add generation capacity to FPL’s system. Rather, this more efficient, lower emissions combustion technology will enable FPL to comply with the NO2 Standard environmental regulation in a cost-effective manner, maintain system reliability, and avoid significant expenditures on increased transmission capability that would otherwise be required if the GTs were simply retired, in lieu of changing out the combustion technologies as proposed.”
Under the plan worked out with the DEP, FPL will be filing permit applications within the next two months for these CT facilities, including a federal greenhouse gas air permit from the U.S. Environmental Protection Agency, the approval for which can take several years to obtain.
DEP has acknowledged that FPL may operate the existing GTs, as permitted, to serve its load requirements until the CTs are in service. To meet the compliance deadline, licensing of the project must begin immediately, and within two months of this filing, FPL plans to file the necessary air construction permit applications for the CTs.
This modification will not result in an increase in FPL’s overall generation capacity; to the contrary, the utility said its total generation capacity will decrease by 300 MW because it will only install enough CTs to continue meeting reliability requirements.
Changing out the technology will require:
- the retirement of 48 GTs at PFL, PPE, and PFM; and
- installation of five new CTs at PFL and three new CTs at PFM. No new CTs will be installed at PPE. Instead, the CTs for Broward County will be consolidated at PFL because of the increased economies of scale by constructing, operating, and maintaining the CTs at one site, the better resources available at PFL, and the need to avoid interference with the modernization construction project that is under way at PPE.
New CTs would fire natural gas, with low-sulfur fuel oil as a backup
The new CT units at both PFL and PFM will use natural gas as the primary fuel when available and also will be capable of burning a light fuel oil, more specifically ultra-low sulfur distillate with a maximum sulfur content of 0.0015% as a back-up fuel.
- For PFL, the project would result in the retirement of 24 of its 35-MW GTs with a combined summer peak capacity of 840 MW and installation of five CTs with a combined summer rating of 1,005 MW.
- For PFM, the project would result in the retirement of 12 of its 54-MW GTs with a combined summer rating of 648 MW and installation of three CTs with a combined summer peak capacity of 603 MW.
- For PPE, the project would result in the retirement of 12 of its 35-MW GTs with a combined summer rating of 420 MW.
FPL estimates that the total cost for the entire project will be $822m. Principal components include the power block at $771m and transmission interconnection and integration at $51m.
The actual CT selection and the Engineering, Procurement, and Construction (EPC) contractor, which represents over 90% of the total project cost, will be based on a competitive bid process.
PFL is located on 392 acres, directly West of Fort Lauderdale/Hollywood International airport. The plant site currently consists of two 442-MW CC units (Units 4 and 5), along with a bank of 24 of the 35-MW GTs used for supplying quick start peak power. All of the units can burn light oil and natural gas. The GT units have a combined peak summer rating of 840 MW and a winter rating of 918 MW with an average heat rate of approximately 16,000 Btu/kWh.
PFM is located on 460 acres, east of 1-75. The plant site currently consists of a nominal 1,400 MW CC (Unit 2), two 150-MW CTs (Units 3A and 3B), along with a bank of 12 of the 54-MW gas turbines GTs used for supplying quick start peak power. All of the units can burn light oil and natural gas, except the twelve GTs which only burn light oil. The GT units have a combined peak summer rating of 648 MW and a winter rating of 710 MW with an average heat rate of about 15,000 Btu/kWh.
FPL is a unit of NextEra Energy (NYSE: NEE).