# ADEQ
ARK A N S A S Departmentof Environmental Quality 

### September 27, 2011 Guy Donaldson, Chief Air Planning Section

- MC 6PD USEPA

- Region 6 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733 Re: Response to Regional Haze SIP Review Questions Mr. Donaldson: In your letter ofSeptember 14,2011, you requested clarification on eight aspects ofthe Regional Haze State Implementation Plan (RH SIP) that was submitted by the Arkansas Department of Environmental Quality in September 2008. The following responses are based on ourreview of the documents that were included in the original submittal and, in some instances, the recollection ofthe AirDivision staffthat participated in the development ofthe RH SIP. For ease ofreview, your questions have been reproduced herein with responses following each. Supporting documentation has been provided in various formats depending on the type ofmedia best suited to the purpose. 1. The Georgia-Pacific Crossett Mill 6A Boiler was included in the table ofBART eligible sources underthe Arkansas Pollution Control and Ecology Commission Regulation 19, Chapter 15, but it was not identified in the RH SIP narrative as being BART eligible (see page 45 ofthe RH SIP narrative). We would like clarification regarding the startup date ofthe boiler, and request that documentation corroborating the startup date ofthe boiler be submitted to us. As you are aware, the startup date criteria for BART eligibility provides that a unit is BART eligible ifit was in existence on August 7.1977, but was not in operation before August 7, 1962. Response: The facility provided ADEQ with a copy ofa document "Boiler

- Report of Inspection

- Standard Form for States and Cities Operating Underthe ASME Code" ( copy enclosed) that was prepared by an inspectorfor The Travelers Indemnity Company. The first inspection ofthis boiler was conducted on 08/06/62 and the report was stamped "paid" on 08/15/62. While we have previously asserted that the boiler could not be considered as "in operation" prior to the issuance ofthe report, ADEQ cannot say this with certainty. The boiler could be considered capable ofoperation as of08/06/62. Despite this uncertainty regarding the date ofstart ofoperations, the boiler was modeled by ADEQ and found to be not subject to BART. A copy ofthe modeling files is enclosed. This information has been previously provided to Region 6 modeling staff.

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS 72118-5317/ TELEPHONE 501-682-0744 / FAX 501-682-0880 www.adeq.state.ar.us

### Guy Donaldson

- USEPA Region 6 September 27,2011

2. The Georgia-Pacific Crossett Mill 9A Boiler was identified as BART eligible in the RH SIP. Even though the visibility modeling provided in Appendix 9.2B ofthe RH SIP shows that the 9A Boiler ofthe Georgia-Pacific Crossett Mill has visibility impacts exceeding the 0.5 dv contribution threshold, ADEQ did not identify the boiler as being subject to BART. ADEQ should clarify how it determined that the boiler is not subject to BART. Ifadditional modeling, not submitted with the SIP, was relied upon to make this determination, we request that this additional modeling and all related documentation be submitted to us. Response: The original modeling that ADEQ conducted was based on the potential emissions described in the Engineering Analysis. Subsequent to this modeling, Georgia-Pacific provided stack test data that allowed for the modeling to be re-conducted with actual emissions. The resulting impacts were below applicability thresholds. Documentation supporting this decision is enclosed.
3. The Great Lakes Chemical Plant Boilers SN-301A and SN-302-A were not identified as BART eligible in the RH SIP, but Great Lakes Chemical is one ofthe facilities ADEQ evaluated to determine ifit is subject to BART. We understand that ADEQ determined that since the two boilers are not integral to the process, they are not BART eligible. We request that ADEQ submit to us the documentation that provided the basis for concluding the two boilers are not integral to the process. Response: Language on Pg. 87 ofArkansas Operating Permit 1077-AOP-Rl states that these boilers are used to "supply the plant with steam." Per an e-mail sent by 

### J. Kordzi, EPA R6 on 06/01106, "These small Category 22 boilers that contribute only energy (e.g. steam or heat) to a process are not considered to be BART-eligible." An excerpted page from Great Lakes Chemical Corporation

- Central Plant Permit No. 1077-AOP-Rl, containing this information, is enclosed. 4. The International Paper/Evergreen Packaging No.1 and No.2 PowerBoilers were not identified as BART eligible in the RH SIP, but International Paperis one ofthe facilities ADEQ evaluated to determine ifit is subject to BART. We understand ADEQ determined the two boilers fall out ofthe startup date criteria for BART eligibility. We request that ADEQ provide supporting documentation regarding the startup date ofthe two boilers. Response: The requested documentation is enclosed. The referenced facility was indeed one of the facilities that ADEQ evaluated in regard to "subject to BART" determinations; however the determinations were made on a unit by unit basis, not a facility-wide basis, as perthe requirements contained within the federal regulations. ADEQ neverconsidered the units listed above to be BART eligible and were not identified as such.
5. The Entergy Lake Catherine Unit 4 was identified as BART eligible and subject to BART in the RH SIP. ADEQ adopted BART emission limits of0.5621b/MMBtu for S02 and 2

### Guy Donaldson

- USEPA Region 6 September 27, 2011 0.037 IblMMBtu for PM for fuel oil firing conditions, but there is conflicting information in the RH SIP regarding what percent sulfurcontent fuel oil corresponds to these emission limits. Sections 3.2 and 5.0 ofthe BART analysis for Lake Catherine Unit 4 both state that use of 1% sulfur content fuel oil is BART for 

### SOz and PM, while the RH SIP narrative states the adopted BART emission limits correspond to use of0.5% sulfur content fuel oil (see Table 9.3a). We request that ADEQ clarify whether0.5% or 1% sulfurcontent fuel oil corresponds to the adopted BART emission limits, and provide documentation (including any pertinent calculations) ofhow the 

### SOz and PM emission limits were derived. Response: The fuel oil Sulfurcontent in the SIP (0.5 wt. %) is correct. Supporting calculations documenting that the SOz emission limits in the SIP are based on 0.5 wt. % Sulfur and the calculations used to develop PM emissions are enclosed. It 

### should be noted that, as per an inspection report dated 07/28/11, this facility is no longer capable ofburning fuel oil. The fuel tanks were emptied and the pipework necessary to bum fuel oil was in the process ofbeing removed. The facility, operated as a peaking unit, does maintain the ability to bum natural gas. While ADEQ does not anticipate modifying the limits in the RH SIP at this time, it appears that the fuel oil-based limits are no longer relevant.
6. In Appendices 5.2 and 5.3 ofthe RH SIP, ADEQ included formulas and other information related to the estimation ofnatural and baseline visibility conditions for its two Class I areas but did not include any actual calculations. We request that these calculations be submitted to us. Response: The natural and baseline visibility conditions calculations were performed off-site by the VIEWS Steering Committee. The resultant values are contained in the "Natural Haze Levels II (version 2) spreadsheet" on the VIEWS web site. [Ref.

- Visibility Information Exchange Web Site (VIEW), accessible at http://vista.cira.colostate.edu/views/weblDataRepositorylDataRepository.htm (accessed 3/19/2008)]. Values in the RH SIP were extracted from this spreadsheet and incorporated in the document.
7. The RH SIP did not contain information regarding the 2002 baseline emissions and emissions resulting from BART controls on sources that Arkansas shared with the CENRAP modeling workgroup for inclusion in the 2002 base case modeling and the 2018 future case modeling. We request that ADEQ submit this information to us. Response: The Base-year modeling inventory was prepared by the CENRAP Modeling Workgroup and consultants and was derived primarily from the 2002 National Emission Inventory. A comprehensive description ofthe manner in which E. H. Pechan and Associates, Inc. prepared and compiled a model-ready inventory is contained in Appendix 7.1-B ofthe RH SIP. For the Future-Yearrun, ADEQ provided the workgroup and Pechan with the controlled BART source emission limits that are contained in Regulation 19 and the RH SIP and they replaced the base-year emissions for these sources with the BART emissions. ADEQ did not
3

### Guy Donaldson

- USEPA Region 6 September 27, 2011 provide these numbers in the form ofemission reductions as this was not required in order to accomplish the task at hand and was not arequirement ofthe Regional Haze Rule.
8. ADEQ performed initial BART screening modeling for all BART eligible sources, in addition to the post-control modeling for all subject to BART sources. However, Entergy hired a consultant (ENSR) to conduct additional CALPUFF modeling for Lake Catherine and White Bluff. Although ENSR's modeling files were referred to in the BART analyses for the two sources, they were not submitted with the SIP. There is also information on PM speciation that was referred to in the submittal, but was not submitted with the SIP. We request that ADEQ submit to us the information on PM speciation and ENSR's modeling files for Lake Catherine and White Bluff. Response: The requested documentation is contained on the CD enclosed herein. Hopefully, the information and documentation contained in this letter and its enclosures will provide you and your staffwith sufficient evidence ofthe diligent efforts ofADEQ's Air Division in its attempt to draft a RH SIP. If, 

### for any reason, additional information would support your review, please contact me directly. Sincerely,

Mike Bates Chief AirDivision
enclosures: Georgia-Pacific Crossett Mill Inspection Report for 6-A Boiler Correspondence with Georgia Pacific regarding Actual Emissions CD containing modeling file for Georgia-Pacific and ENSR files for Entergy Excerptedpage from Great Lakes Chemical Corporation Permit 1077-AOP-Rl PDF File ofCorrespondence with International PaperDocumenting Age ofBoilers S02 and Particulate Emission Calculations for Entergy
- Lake Catherine Fuel Oil Burning



### 4StandQr!:f Form for States and Cities Operating Under the ASME Cod" 

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Indemnity Company 11 REQUIREMENTS (U,I ••.1. vIolallon.)

NAME AND TITLE OF PE.RSON TO WHOM REQUIREMENTS WERE EXPLAINeD 

### \ 

# AUG 15 1962

# .. Georgia.pacific

January 26,2007 Mike Bates Chief, Air Division Arkansas DepartmentofEnvironmental Quality Post Office Box 8913 Little Rock, AR 72219-8913 RE: Georgia-Pacific LLC CrossettPaper BART Emissions AFIN: 02-00013 PennitNumber: 597-AOP-R8 DearMr. Bates: Georgia-Pacific Corporation Consumer Products 100 Mill Supply Road P. O. Box 3333 Crossett, AR 71635 (870) 567-8000 {870} 364·9076 fax V'lww.gp.com

lbis letteris in follow-up to an e-mail from Mary Pettyjohnin regards to the BART determination for Georgia-Pacific LLC Crossett Paper Operation. Ms. Pettyjohn requested that we summarize ourparticipation in the BART process and present to you the combined findings ofthe Department and Georgia-Pacific. Initially, the Department developed apreliminary list ofBART-eligible facilities from readily-available information. Forour facility, the 9A Boiler (SN-22) was flagged as being old enough and large enoughto be subject to BART. The Department informed us ofthis and asked us to quickly gather actual emissions data for PMIO, S02, and NOx for the years of2001, 2002, and 2003. The Departmenthad a short time-frame to formulate its BART strategy, and as such, could not give us much time to respond. Because it would be extremely difficult to gatherthe requested S02 data given the time constraints and because there was norecent stack testing data for S02 at that source, Georgia-Pacific instead submitted the permitted potential emissions for that time period (which were based on AP-42 factors that did not include emissions scrubbing by the bleach plant water). This approach was deemed to be the most conservative, and Georgia-Pacific submitted it to allow for the Departmentto meet its deadlines. However, the use ofpotential worst-case emissions in the dispersion model, as opposed to a more realistic emissions figure basedon source-specific testing, resulted in the Department's determination that we did fall underthe criteria ofBART regulations. Since that time, we have performed stacktesting that gives more accurate data for 802 emissions. The facility uses a scrubberfor particulatecontrol on the 9A Boiler, and the waterused in this scrubber is from thebleach plant. It has been established at othermills, and now at ours, that the make-up ofthatwater scrubs out an appreciable amount of802 emissions. This scrubberwas used inthis mannerduring the BART applicability period of2001, 2002, and 2003.In the e-mail from Ms. Pettyjohn referenced above, she included the updated modeling results. The results show that the 6A Boiler and 9A Boiler, modeled individually and combined, do not contribute a change in deciview (dv) equal to or greater than (=» 

### 0.500 dv and do not cause a change in dv => 

### 1.00 dv and thus are not subjectto BART controls. Her results are included 

### as an attachment to this letter. Using the updated model results, Georgia-Pacific believes that the 6A and 9A Boilers should no longerbe considered as BART regulated sources. We respectfully request that the Department review our combined findings and respond in writing with your concurrence. Ifyou have any questions, please contact Mark Aguilar at (404) 652-4293, Michael Watt at (870) 567-8188, ormyselfat (870) 567-8144. We appreciate all yourhelp in this matter. Sincerely,

# ~~~bJ.tJ&,;t£**o::~:~.** Cutbirth Supt. Environmental Services Georgia-Pacific LLC
cc: Mark Aquilar, Georgia-Pacific LLC Michael Watt, Georgia-Pacific LLC
mhw enclosure



### 3Copy of GPCR BART Results from Actuals

No ofdays No ofdays No ofdays No ofdays No of days No ofdays**wlth~ wlth~** **wlth~** with ().dy with a>-dv with ().dy =>0.50 for =>1.00 for Maximum =>0.50 for =>1.00 for Maximum =>0.50 for =>1.00 for Maximum Facility NamelLocation (BART File Name) !-iass I Area 2001 2001 a> dv 2002 2002 a>cIv 2003 2003 CDdv Georgia-Pacific PaperICrossett (GPCR) CACR 0 0 0.167 0 0 0.339 0 0 0.221 HEGL 0 0 0.089 0 0 0.312 0 0 0.136 MING 0 0 0.132 0 0 0.095 0 0 0.162 SIPS 0 0 0.147 0 0 0.144 0 0 0.333 UPBU 0 0 0.116 0 0 0.101 0 0 0.368 Note: O>-dv

## = change in deciview

.. CACR

# = Caney Creek Wilderness Area, AR; HEGl

## =Hercules-Glade Wilderness Area, MO; MING = Mingo Wilderness. MO; SIPS

# = Sipsey Wilderness Area, Al; UPBU = Upper Buffalo Wilderness Area, AR

Prepared by Mary Pettyjohn 1/26/2007 Page 1

# .. Georgia.pacific

January 26, 2007 Mike Bates Chief, AirDivision Arkansas Department ofEnvironmental Quality PostOffice Box 8913 Little Rock, AR 72219-8913 RE: Georgia-Pacific LLC CrossettPaper BART Emissions AFIN: 02-00013 Permit Number: 597-AOP-R8 DearMr. Bates: Georgia-Pacific Corporation Consumer Products 100 Mill Supply Road P. O. Box 3333 Crossett, AR 71635 (870) 567-8000 (870) 364-9076 fax www.gp.com

This letteris in follow-up to an e-mail from Mary PettY,johnin regards to the BART determination for Georgia-Pacific LLC Crossett PaperOperation. Ms. Pettyjohn requested that we summarize ourparticipation in the BART process and present to you the combined findings ofthe Department and Georgia-Pacific. Initially, the Department developed apreliminary list ofBART-eligible facilities from readily-available information. Forour facility, the 9ABoiler (SN-22) was flagged as being old enough and large enough to be subject to BART. The Department informed us ofthis and asked us to quickly gather actual emissions data for PMIO, S02, and NOx for the years of200I,2002, and 2003. The Department had a short time-frame to fonnulate its BART strategy, and as such, could not give us much time to respond. Because 

### it would be extremely difficult to gather the requested S02 data given the time constraints and becausethere was no recent stack testing data for S02 at that source, Georgia-Pacific instead submitted thepermittedpotential emissions for that time period (which were based on AP-42 factors that did not include emissions scrubbingby the bleachplant water). This approach was deemed to be the most conservative, and Georgia-Pacific submitted itto allow for the Departmentto meet its deadlines. However, the use ofpotential worst-case emissions in the dispersion model, as opposed to a more realistic emissions figure based on source-specific testing, resulted in the Department's determination that we did fall underthe criteriaofBART regulations. Since that time, we have performed stack testing thatgives more accurate data for S02 emissions. The facility uses a scrubber for particulatecontrol on the 9A Boiler, and the water used in this scrubber is from the bleach plant. It has been established at othermills, and now at ours, that the make-up ofthat water scrubs out an appreciable amount ofS02 emissions. This scrubber was used in this mannerduring the BART applicability period of2001, 2002, and 2003.We used the stack testing datato detennine a more accurate emission factor for 802 emissions. Then we used that factor with the worst-case actual monthly fuel usage for that time periodto determine an emission rate. We then submitted updated maximum emissions to the Department. The updated emissions are also included in the following table: 

### 9A BoilerEmission Rates Year 

### 2001 2002 2003 Maximum Hourly 90.01blhr 90.01blhr 90.01blhr

PMIO Emissions Maximum Hourly 306.71b/hr 306.71blhr 306.71blhr

802 Emissions Maximum Hourly 244.01blhr 244.01b/hr 244.01blhr

NOx Emissions At about this same time, Georgia-Pacific

### was informed by the Department that it had found documentation that the 6A Boiler (8N-19) was inspected on August 6, 1962 and had ahydrostatic test on July 3, 1962. These dates brought the 6A Boiler's BART eligibility into question 

### as well. Georgia-Pacific searched its own records and did not find any documentation that would demonstrate that there was no steamproduction during the triggerperiod. We then gathered records offuel usage for the 6A Boilerduring the years of2001, 2002, and 2003 to allow for calculation ofmaximum daily emissions for PMIO, 802, and NOx. While the boileris pennitted to bumoil, natural gas was the only fuel burned during that period. We calculated emissions using AP-42 factors and the worst-case daily fuel usage. Theresults were submitted to the Department and are also included in the table below: 

### 6A BoilerEmission Rates Year 

### 2001 2002 2003 Maximum Daily 7,772MCF 5,685 MCF 5,039 MCF Gas Usage Maximum Hourly 2.461blhr 1.801blhr 1.601blhr PMIO Emissions Maximum Hourly 0.191b/hr O.l4lblhr O.13lblhr

802 Emissions Maximum Hourly 32.381blhr 23.681blhr 21.00lblhr

NOx Emissions

2In the e-mail from Ms. Pettyjohn referenced above, she included the updated modeling results. Theresults show thatthe 6A Boiler and 9A Boiler, modeled individually and combined, do not contribute a change in deciview (dv) equal to or greater than (=» 0.500 dvand do not cause a change in dv 

### => 1.00 dv and thus are not subjectto BART controls. Herresults are included as an attachment to this letter. Using the updated model results, Georgia-Pacific believes that the 6A and 9A Boilers should no longerbe considered as BARTregulated sources. We respectfully request that the Department review our combined findings and respond in writing with your concurrence. Ifyou have any questions, please contact Mark Aguilar at (404) 652-4293, Michael Watt at (870) 567-8188, ormyselfat (870) 567-8144. We appreciate all yourhelp in this matter. Sincerely,

# ~~~w.t~-tt**(/:n~~~.** Cutbirth Supt. Environmental Services Georgia-Pacific LLC
cc: Mark Aquilar, Georgia-Pacific LLC Michael Watt, Georgia-Pacific LLC mhw enclosure



### 3

### ATIACHMENTA BART Modeling ResultsCopy ofGPCR BART Results from Actuals

No of days No ofdays No ofdays No ofdays No of days No of days with (])..dv with Ol-dv with Ol-dv with a>-dv with Ol-dv with (])..dv =>0.50 for =>1.00 for Maximum =>0.50 for =>1.00 for Maximum =:>0.50 for =>1.00 for Maximum Facility NamelLocation (BART File Name)**~laS$IArea** 2001 2001 Ol dv 2002 2002 Q)dv 2003 2003 Oldv Georgia-Pacific PaperI Crossett (GPCR) CACR 0 0 0.167 0 0 0.339 0 0 0.221 HEGl 0 0 0.089 0 0 0.312 0 0 0.136 MING 0 0 0.132 0 0 0.095 0 0 0.162 SIPS 0 0 0.147 0 0 0.144 0 0 0.333 UPBU 0 0 0.116 0 0 0.101 0 0 0.368 Note: Ol-dv

## = change in deciview

* CACR

# = caney Creek Wilderness Area, AR; HEGL = Hercules-Glade Wilderness Area, MO; MING

# = Mingo Wilderness, MO; SIPS

# = Sipsey Wilderness Area, AL; UPBU = Upper Buffalo Wilderness Area. AR

Prepared by Mary Pettyjohn 1/26/2007 Page 1Great Lakes Chemical Corporation

- Central Plant Permit: 1077-AOP-Rl AFIN: 70-00012 Boilers and NaHS Process SN.301, 302,303,902,906,907, and 908 Boiler#2, Boiler#3, Boiler#4, SourGas Flare, Cooling Towers Source Description Boilers Great Lakes Chemical Corporation operates three boilers which supply the plant with steam. Boiler #2 (SN-301) is a 150 MMBTU/hrboilerwhich is permitted to operate on pipeline quality natural, fuel gas from the NaHS Plant, or "sweetened" gas from the N Amine unit at Lion Oil Company's facility. Boiler #3 (SN-302) is a 113 MMBTU/hr boiler which fires pipeline quality natural gas and "sweetened gas from Lion Oil's N Amine Unit. Boiler#4 (SN-303) is an 88.6 MMBTUlhrboiler which fires only pipeline quality natural gas. This boiler is subject to the requirements ofNSPS Subpart Dc. Boiler#2 and #3 have been permitted in the past to combustfuel oil in times ofnatural gas curtailment. The boilers no longer have the capability offiring fuel oil. NaBS Process Thc major steps in the production are: Sour gas and sodium hydroxide (caustic) are reacted, NaBS product is stored in tanks, and NaHS product is shipped via truck. The various NaBS storage tanks are insignificant activities under category B-2 I. Cooling towers, SN-906, 907, and 908, are used to cool the process water used in the NaHS unit. Sour Gas Handling and Flaring Operations Brine is pumped to the surface from the underlying Smackoverfoundation at GLCC's brine supply wells. The brine may contain dissolved hydrogen sulfide gas (sour gas) and oil, which must be separated from the brine before it is sent to the bromine towers. The brine and sour gas streams are piped to the plant. The crude oil is stored in tanks for future sales. From the Central Plant GLCC processes the combined sour gas streams in one ofthe following ways: Scenario #1: Amine Operation. The combined sour gas streams are transported viapipeline to Lion Oil Company, a neighboring petroleum refinery, where the sour gas is processed in Lion Oil's amine unit and returned as "sweet gas" to GLCC for use as fuel in boilers #2 and #3; and/or Scenario #2: NaBS/Amine Operation. All or a portion ofthe combined sour gas streams are processed in GLCC's Sodium Hydrosulfide Plant (NaHS Plant) where the sour gas is partially sweetened and the partially sweetened gas is routed to Lion Oils amine unit for furtherrefinement and sweet gas is returned to GLCC for use as a fuel in boilers #2 or#3; or Scenario #3: NaHs Operation. When the sulfur-containing gas stream (sour gas orpartially sweetened NaHS gas) cannotbe routed to Lion Oil's amine unit, the combined sour gas streams are processed in GLCC's NaHS unit where the sour gas is sweetened and the NaHS gas is routed directly to GLeC's Boiler#2 for use as fuel. In the event ofa startup, shutdown, malfunction, or upsetcondition ofLion Oil's amine unit, the NaHS unit, or equipment integral to the processing ofthe combined sour gas streams, GLCC's sour gas will be combusted in 87

# ADEQ
ARK A N S A S Department of Environmental Quality 

### August 30,2006

Ms. Kelly D. Bryant Environmental Group Leader International Paper Company P.O. Box7069 Pine Bluff, Arkansas 71611-7069 Re: BART Eligibility of Power Boilers 1 and 2, SN-13 and SN-15 Dear Ms. Bryant: This letter is to notify you that Power Boilers one and two were inadvertently classified as being BART-eligible due to erroneous information in the permit application. Therefore, neither boiler is subject to BART. The data you supplied by fax on August 24, 2006 was sufficient to research the true ages of the two boilers. The Arkansas Department of Labor, Boiler Inspection Division, inspected both boilers on May 27,1958 and issued Annual Inspection Certificates for the two boilers June 26, 1958. Enclosed are copies ofthe inspection certificates. The new information does not require a modification to the permit at this time. But the information should be included in the next permit application submitted for a modification or renewal. The changes will be in the source description and the Emission Rate Table. Sincerely,

# ~£.~~ William E. Swafford Engineer, P.E. cc: Tom Rheaume Mary Pettyjohn

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## BOILER INSPECTION Little Bock, Ark. BOILER



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## IEntergy Lake Catherine is permitted to burn #6 fuel oil. The average BTUs in a gallon of #6 fuel oil is 153,000. A gallon of#6 fuel oil has an average density of 8.3 pounds (Ibs). One pound (Ib) of sulfur produces 2 Ibs of sulfur dioxide.

0.562 lbs Sulfur Dioxide 

## * lIb SUlfur 

## * 153,000 BTUs
. 

## * 1 Gallon #6 Fuel Oil = 0.00517988 

### *100 = 106 BTUs 2 lbs SulfurDioxide 1 Gallon #6 Fuel Oil 8.31bs .5%Sulfur/ lb Entergy Lake Catherine Unit 4 is a tangential boiler with a maximum heat input of 5850 MMBTUs/hr. From AP-42 page 1.3-13 Total condensable particulate matter 2.5 (PM 2.S) Emission Factor (EF) = 1.5 Ibs/103 gallons From AP-42 page 1.3-15 uncontrolled utility boilers PM 2.S EF = 4.3A Where A= 1.12(5) +0.37 and 5 = 0.5 A = 1.12(.5) +0.37 A = 0.93 Therefore, PM 2.S= 4.3(0.93) = 4 Ibs PM 2.s /103 gallons Total PM 2.5 = 1.5 +4 = 5.5 Ibs/l03 gallons Boiler specs = 5850 MMBTUs/hr From AP-42 page 1.3-8 150 MMBTUs/l03 gallons
5850 MMBTUs 

### * 103gallons = 39 X 103 II n /h hr 150MMBTUs ga 0 s r 39 X 103gallons 

### * 5.51bs = 214.5 Ibs/hr hr 103gallons 214.51bs hr hr 

## * 5850 MMBTUs = 0.0366 Ibs/MMBTUs = 0.037 Ibs/MMBTUs