Blakley, Robert

From:

Sent:

To:

Subject:

John Graves [jgraves@minnkota.com]

Thursday. April 12, 2007 3:57 PM

Blakley, Robert

Fw: Revised Draft of Combined BMcD and EERC Responses to NDDH &E PA SCR

and Non-SeR MRY NOx BACT Issues PA SCR and Non-SeR MRY NOx BACT Issues

See below. Steve's response would certainly be correct for a low dust

application and may be correct for a tail-end application.

John T. Graves, P.E.

Environmental Manager

Minnkota Power Cooperative, Inc.

P.O. Box 13200

Grand Forks, N.D. 58208-3200

Tel: (701) 795-4221

Fax: (701) 795-4214

Forwarded by John Graves/Legal/Minnkota on 04/12/2007 03:55 PM -----

John,

"Benson, Steven

A. • <sbenson@undeerc.

org>

rr4/12/~007 03:18

PM

To

• . jgraves@minnkota. cOm' • <jgraves@minnkota.com>

cc

Subject

He: Revised Draft of Combined BMcD

and EERt: ReSPonses Lo NDDH & E

PA SCR and Non-SCR MRY NOx BACT

Issues PA SCR and Non-SCR

MRY NOX BACT Issues

I think the analysis are still valid. Most of the particulate removal takes place in the

esp. I assume that the scrubber does not have a big impact on aerosol removal. OUr

original intent was to prove the removal downstream of a particula.te control device.

Correct?

We may want to check to make sure in May and have the info available if we get

questioned.

I do not think we should hold up the response.

Steve

S,Leve Benson. Message sent from Bla,ckberry

Original Message -----.-

FrolTl: John Gr.aves ~jgraves@minnkota_cbm>

To: Blakley, Robert <rblakley@burnsmcd.com>

1
Cc: Weilert, Carl <cwei1er@burnsmcd.com:>;John Graves <jgraves@minnkota.com:>; Steve Benson

<spenson@undeerc.org>; Voss, Steve <svoss@burnsmcd.com>

Sent: Thu Apr 12 14:11:19 2007

Subject: Re: Revised Draft of Combined BMcD and EERC Responses to NDOH & EPA SCR and NonseR MRY ~Ox BACT Issues

I have made some changes/comments/questions on pages 24.34-36.

Additionally, I just learned that the filter samples that were analyzed by Steve Benson

were obtained under normal operating conditions on Unit 2. I had discussed with Kevin

Thomas the closing of the bypass damper to simulate the scrubber's future configuration.

However, there Was a miss-communication and the closing ·of the damper did not occur. The

bypass at the time was approximately 18 %. Our next opportunity to sample with the

bypass damper closed will be on May 23. This may not only impact this response letter, but

also the vendor inquiry. Steve - Does it make a large impact or is your analysis still

valid.

~ohn T. Graves, P.E.

Environmental Manager

Minnkota Power Cooperative, Inc.

P.O. Box 13200

Grand Forks, N.D. 58208-3200

Tel: (701) 795-4221

Fax: nOl) 795-4214

"Blakley, Robert"

<rblakley@burnsmc

d.com:>

04/1112007 04:27

PM

John -

To

"John. Graves"

<jgraves@rninnkota.cbm:>

cc

"Weilert. Carl"

<cwei1er@burnsmcd.com>. "Voss,

Steve" <svass@burnsmcd.cciin>, "Steve

Benson" <sbenson@undeerc.org>

Subject

Revised Draft of Combined BMcD and

EERC Responses to NDOH & EP~ SCR

and Non-SCR MRY NOx BACT .Issues

We have revised the previous draft emailedon4/10/07thatinc1udesSteveBenson.sminor

additions for the discussion of the fine partiCUlate electron microscope photographs .

involving the issues for low-dust SCR fouling now located on page 21. This version still

provides a combined response to NDDH's February 1. 2007 letter with January 26th EPA

letter attached. This draft version essentially uses EERC's 4111/07 revisions of the 4/10

emailed version of Burns & McDonnell's proposed responses. This also inco.rporates the

changes you sent on 4/1Q from the previous (4/3) versibn. and contains revised language

that we discussed this afternoon (4/11). It also deleted much of the language (as you

suggested> that i,s subsequently covered in the SCR vendor query letter document being

finalized.

This is almost ready to send to the NODH and EPA; bowever this version has not heen

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through Our quality review process. Nevertheless, I wanted to let you see what the latest

version looks like. Note that this does NOT include results from proposals from vendors

that the EPA has requested in their January 26 letter.

Once you confirm acceptance of the latest changes, now easily visible from the "Track

Changes" feature, we will only need to finish our internal quality review and the SCR

vendor query letter document in order to be able to complete this for final issuance.

Bob Blakley

Burns & McDonnell

(816) 822-3842 (See attached file·: BMcDJIDDH 4_11_07 (draft) .doc)

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