### Blakley,Robert
From: Sent: 

### To: Subject: JohnGraves[jgraves@minnkota.com] Thursday.April12,20073:57PM Blakley,Robert Fw:RevisedDraftofCombinedBMcDandEERCResponsestoNDDH

### &E PA SCR andNon-SeRMRYNOxBACTIssues PA SCRandNon-SeRMRYNOxBACTIssues



### See below. Steve's response would certainlybe 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 

### Forwardedby 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-SCRMRY 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 ifwe get questioned.

I 

### do not think we shouldholdup 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> 1Cc: 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 thatwere 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 letterwithJanuary 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 SCRvendor query letter document being finalized.

This is almost ready to send to the NODH and EPA; bowever this version has not heen 2

### through Our quality reviewprocess. Nevertheless, I wanted to let you see what the latest version looks like. Note that this does NOT include results fromproposals from vendors that the EPAhas requested in their January 26 letter. Once you confirmacceptance 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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