1 Medina, Dayana

From: kpgaus@aep.com
Sent: Friday, June 21, 2013 3:39 PM

To: pettyjohn@adeq.state.ar.u s; Medina, Dayana
Cc: kjmunson@aep.com; tbbond@aep.com; jjhenry@aep.com; wemast@ aep.com; bwmoore@aep.com; jchendricks@aep.com; jmmcmanus@aep.com; kbrandall@aep.com; scarney@aep.com; cfhandley@aep.com; jjewell@ trinityconsultants.com Subject: Re: FW: Region 6 comments on AEP Flint Creek

Attachments: flint_creek_bart_respones_june_2013.pdf

Mary and Dayana,

Attached are responses to the below questions. I am sending a hard copy to both of you that also will have a CD with all
of the attachments referenced in the letter. Let me know if you have any questions.

Kris Gaus, QEP

American Electric Power Air Quality Services
office: 214/777-1113
fax: 214/777-1138

"Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us>

05/22/2013 09:29 AM To "Kris Gaus (kpgaus@aep.com)" <kpgaus@aep.com>, "Brian Bond (tbbond@aep.com)" <tbbond@aep.com>

cc "Davis, Anthony" <DavisA@adeq.state.ar.us>, "McCorkle, Mark" <MAC@adeq.state.ar.us>, "Rheaume, Thomas" <RHEAUME@adeq.state.ar.us>, "Brown, Derrick" <brownd@adeq.state.ar.us>, "Parker, Paula" <PARKERP@adeq.state.ar.us>

Subject FW: Region 6 comments on AEP Flint Creek

This is an EXTERNAL email. STOP. THINK bef ore you CLICK links or OPEN attachments.

Here are Region 6’s comments.

From: Medina, Dayana [ mailto:Medina.Dayana@epa.gov ]

Sent: Wednesday, May 22, 2013 9:02 AM

To: Pettyjohn, Mary

Cc: Donaldson, Guy; Feldman, Michael Subject: Region 6 comments on AEP Flint Creek

Hi Mary,2 Here are Region 6’s comments regardi ng the most recent version of the AEP Flint Creek BART report and the updated cost spreadsheets and other information provi ded by AEP/SWEPCO via emai l on 4/11/13. Please let me know if you’d like to discuss.

NOx

It does not appear that any new information was provide d related to the cost estimate for the NOx control options. As we indicated in commen ts provided on 02/08/2013, very little documentation has been provided for the capital and operating costs for the LNB/OFA and SCR control options . In particular, for the LNB/OFA option, there is no breakdown provided for the estimated capital and installation co sts. A breakdown of these costs should be provided, along with a copy of any pertinent document s related to the “Public Service

Commission Docket 12-008-U” referenced under footnot e 1, and any other docum entation to support the

LNB/OFA cost estimate. We also not e that the LNB/OFA cost estimate assumes a 15 year equipment life. Unless proper documentation is provided to demonstrate that the anticipated equipm ent life of this control option is limited to 15 years, we believe that an anticipat ed 30 year equipment life w ould be more appropriate to use in the cost analysis. The cost estimate for the S CR option also provides no brea kdown of the capital costs and very little detail of the O&M cost s. Footnote 1 indicates that the SCR capital and O&M cost estimates were developed by AEP based on engineering estimates that were informed by AEP’ s experience with SCR

installation at other plants owned by AEP. Please provide documenta tion to support the SCR cost estimate. In addition, we note that the SCR cost estimate assumes a 20 year equipment life. Unless proper documentation is provided to demonstrate that the anticipated equipment lif e of SCR is limited to 20 ye ars, we believe that an anticipated 30 year equipment lif e would be more appropriate to use in the cost analysis.

In addition, as we noted in previous written comments , additional justification should be provided for the

selection of 0.23 lb/MMBtu as the NOx BART emission limit using LNB/OFA. The BART report states that this limit was selected based on experience with sim ilar boilers and vendor disc ussions. A vendor quote should be provided or a list of similarly configured boilers should be compiled along with emissions data from CAMD for these similar boilers in support of the 0.23 lb/MMBtu NOx BART emission limit fo r the Flint Creek unit.

Modeling

Please provide a copy of the EPRI calc ulations used to estimate SO4 emi ssions for all modeling scenarios.

Thank you,

Dayana Medina

U.S. Environmental Protection Agency, Region 63 Multimedia Planning and Permitting Division

Air Planning Section (6PD-L)

214-665-7241