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Medina, Dayana

From: kpgaus@aep.com

Sent: Friday, June 21, 2013 3:39 PM

To: pettyjohn@adeq.state.ar.us; 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 before 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, 

 
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Here are Region 6’s comments regarding the most recent version of the AEP Flint Creek BART report and the 

updated cost spreadsheets and other information provided by AEP/SWEPCO via email on 4/11/13. Please let 

me know if you’d like to discuss. 

 

 

NOx 

It does not appear that any new information was provided related to the cost estimate for the NOx control 

options. As we indicated in comments 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 costs. A breakdown of these 

costs should be provided, along with a copy of any pertinent documents related to the “Public Service 

Commission Docket 12-008-U” referenced under footnote 1, and any other documentation to support the 

LNB/OFA cost estimate. We also note that the LNB/OFA cost estimate assumes a 15 year equipment life. 

Unless proper documentation is provided to demonstrate that the anticipated equipment life of this control 

option is limited to 15 years, we believe that an anticipated 30 year equipment life would be more appropriate to 

use in the cost analysis. The cost estimate for the SCR option also provides no breakdown of the capital costs 

and very little detail of the O&M costs. 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 documentation 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 life of SCR is limited to 20 years, we believe that an 

anticipated 30 year equipment life 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 similar boilers and vendor discussions. 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 for the Flint Creek unit. 

 

Modeling 

Please provide a copy of the EPRI calculations used to estimate SO4 emissions for all modeling scenarios. 

 

 

 

Thank you, 

 

Dayana Medina 

U.S. Environmental Protection Agency, Region 6 
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Multimedia Planning and Permitting Division 

Air Planning Section (6PD-L) 

214-665-7241