GREG FISCIIER 

t.f."-YOR 

May 19, 2015 

Beverly Banister 

Director 

A 

AIR POLLUTION • CONTROL DISTRICT 

LOUISVILLE, KENTUCKY 

Air, Pesticides, and Taxies Management Division 

US EPA, Region 4 

Sam Nunn Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, GA 30303 

K~11llll 1'AIIEY Sl!. . 

OJIU!CTOR 

Subject: Clean Air Act (CAA) 11 O(l) Non-Interference Demonstration to support the approval 

of the source specific Nitrogen Oxides (NOx) Reasonably Available Control 

Technology (RACT) plan for Louisville Gas & Electric Cane Run Generating Station 

(LG&E Cane Run) KY 214 

Dear Ms. Banister: 

The Louisville Metro Air Pollution Control District (APCD) is submitting the 

following Non-Interference Demonstration for Louisville/Jefferson County, Kentucky to 

support the Environmental Protection Agency's {EPA) approval of the State Implementation 

Plan (SIP) submittal KY 214. On February 13, 2013, the Kentucky Division for Air Quality 

{DAQ) submitted to EPA on behalf of APCD a source specific NOx RACT plan for LG&E 

Cane Run. CAA Section 110{1) prohibits EPA from approving any proposed SIP revision that 

interferes with the attainment and maintenance of the National Ambient Air Quality Standards 

(NAAQS) in effect at the time of the revision. The supplemental information requested by 

EPA demonstrates that the proposed source specific NOx RACT plan for LG&E Cane Run 

does not interfere with any applicable requirement concerning attainment and reasonable 

further progress, or any other applicable requirement as required by Section 11 0(1) of the 

federal CAA. 

I. Background 

WWW.LOUtSVILLEKY.COV 

WWW.LOUISVJLLEKY.GOVIAPCD 158 BARRET AVE:-IVE, ROOM 205 LOUISVILLE, KENTUCKY 40204- 1745 
Beverly Banister, Director 

May 19,2015 

Page Z ofS 

In response to the NOx SIP caU, APCD adopted Regulation 6.42 Reasonably Available 

Control Technology Requirements for Major Volatile Organic Compound and Nilroge, Oxides 

Emitting Facilities on February 2, 1994. Regulation 6.42 Section 1.2 establishes the 

requirements for RACT determination, demonstration, and compliance for Volatile Organic 

Compounds (VOC) and NOx emitting facilities. Furthermore, Regulation 6.42 requires APCD 

to submit each source specific RACT determination to the EPA for approval into the SIP. 

APCD submitted the regulation for approval into the SIP on May 21, 1999 and the EPA 

published approval in the Federal Register at 66 FR 53658 and 66 FR 33216. 

To comply with Regulation 6.42, LG&E submitted a NOx RACT analysis for the coalfired units 4, 5 and 6 (U4, U5, and U6) for Cane Run in July 1994. In response> on November 

8, 1999, APCD proposed and the Air Pollution Control Board (Board) adopted a NOx RACT 

plan establishing emission rates for NOx. The EPA suggested several improvements and 

Amendment 1 ofthc NOx RACT plan was adopted on October 18,2000. The EPA published 

approval for the plan in the Federal Register at 66 FR 33512 a~66 FR 5366p JO(':J. 3 jot 

On June 13,2011, LG&E submitted an application to construct a new natural gas-fired 

combined cycle generating facility (NGCC Unit) (U 15 and U 16) and retire U4, US, and U6 at 

Cane Run to comply with new federal requirements, including the Mercury & Air Toxics 

Standards (MATS) and Cross-State Air Pollution Rule (CSAPR). In response, on July 18, 

2012, APCD proposed and the Board adopted Amendment 2 establishing emission rates for 

1\0x. 

11. Supplemental Information 

Table 1 presents the coal-fired electric generation (U4, US, and U6) figures for 

capacity, the NOx limits per RACT, NOx allowable per year and VOC emissions. The NOx 

RACT limits range from 0.47 to 0.52 Jb/MM Btu, the total NOx allowable per year is 13,053 

tons and the possible VOC emissions total 73.9 tons per year (tpy). 

Table 1. Coal-Fired Electric Generation (U4, US, & U6) 

NOx NOx 

Unit limits per Allowable 

Unit Capacity RACT per year voc 

(lb/MM 

(MMBtulhr) Btu) (tonlyr) (tpy) 

U4 1,639 0.52 3.733 20.3 

U5 1,875 0.52 4,271 23.2 

U6 2,453 0.47 5,050 30.4 

Total for coal boilers 13,053 73.9 

Rt:ferenccs~ 

I. Permit 175-00-TV {R2), DM #68067. 

2. 20 l3 Emission Inventory, DM #65726. 

3. Plant wide PTE for Cnne Run, DM #61551. 

Table 2 presents the new NGCC Unit (U15 and Ul6) figures for capacity, the NOx 

limits per RACT, NOx allowable per year and pennitted allowable VOC emissions. The NOx 
Beverly B1mistcr, Director 

May 19,2015 

Page 3 ofS 

RACT limit for U15 is 0.43 lb!MWh and 3.6 Jb/hr for U16. The total NOx emissions 

allowable per year is 1,393 tons and the possible VOC emissions total 99.1 tpy. 

Table 2. NGCC-Fired Electric Generation (U15 & Ul6) 1 

NOx NOx 

Unit limits per Allowable 

Unit Capacity RACT p_er year VOC 

U15 MW lb/MWh tonlyr (tpy) 

(NGCC) 731 0.43 1,377 97.0 

U16 MMBtulhr lblhr tonlyr (tpy) 

(Auxiliary 

Boiler) 59.9 3.6 15.8 2.1 

Total for NGCC and Aux. boiler 1,393 99.1 

References: 

1. Permit175·00-TV (R2), DM #68067. 

2. 2013 Emission lnventory, OM #65726. 

3. Plant wide PTE for Cane Run, DM #6155 I. 

A comparison of Table 1 and 2 demonstrates a significant reduction of 11, 660 tpy of 

NOx allowable emissions. According to the 2013 emission inventory data, the NOx emissions 

for the coal-fired boilers at LG&E Cane Run are 30% of the total NOx emssions from Title V 

sources in Jefferson County. Conversion to the NGCC Unit, with a NOx allowable per year of 

just 1,393 tpy, will have a considerable postive impact on the air quality in Louisville/Jefferson 

County. 

The comparison also indicates a possible increase of25.2 tpy ofVOC emissions. 

However, any possible increase in VOC emissions will be offset by the reduction in NOx 

emissions. Table 3 summarizes an APCO analysis of ozone sensitivity based on data from 

monitors in the Louisville Metropolitan Statistical Area and a region-wide modeling project 

known as the "Southeastern Modeling, Analysis, and Planning" (SEMAP).2 SEMAP, initiated 

by Southeastern States Air Resource Managers (SESARM), Inc. is an integrated assessment 

using a one-atmosphere modeling approach to aid member states in the development of SIPs 

for 0 3 and PM2.s. and address the air pollution problems in the SESARM states. 

1 The table excludes lhe emission calculations for the fuel gas dew point heater (UI7) because it will not be 

constructed. 

2 Odam, Talat, and Zac Adelman. Emissions and Air Quality Modeling for SEMAP. Georgia Institute of 

Technology Environmental Engineering Department, the University ofNorth Carolina Institute for the 

Environment and the Colorado State University Cooperative Institute for Research in the Atmosphere. October 

15,2014. 
Beverly Hamster, Director 

May 19,2015 

Pagc4 ofS 

Table 3. Louisville MSA Ozone Sensithitr 

Sensitivity of 0 3 to Reductions of NOx and VOC 

I I Tons per day of03 reduced 

Monitoring Site County NOx voc 

Shepardsville I 

#210290006 Bu11itt -1 6.492864 73 -1.773531185 

Elizabethtown 

#210930006 I Hardin I -16.33448501 -0.978168872 

Bates Elementary 

#211110027 Jefferson -12.46735753 -5.518252679 

Watson Lane . 

' 

#211110051 Jefferson -14.52759258 -2.208531284 

WLKY-TV 

#211111021 Jefferson -9.3 70160048 -4.649527701 

Buckner I 

~ #211850004 Oldham -13 .98681808 -1.92340706 

RefercncL'S' Average I. Data is from the SE\tAP proj ect (2009-2(114) which made usc Minimum of robust emt5sions modeling platfonns dc\·clopcd from data 

collct:tcd by SESAIUvl states, and c1<tcnsh·c modding tools Maximum 

1mplcmL'1llcd h> the SEMAP modelmg u:um. 

2. A 200 7 baseline was de\' eloped prior to a 2018 year projection, 

from v.hich SL'flsiti\itics where calculillcd. 

NOx/VOC 

Ratio 

9.299 

16.699 I 

2.259 

6.578 

2.015 

7.272 

7.354 

2.015 

16.699 

The analysis demonstrates that NOx emission reductions are 2-16 times more effective 

than VOC emission reductions at reducing ozone concentrations. Conservatively, a twenty-five 

ton increase in VOC emissions can be offset with a fifty ton reduction in NOx emissions. Thus, 

the potential increase of 25.2 tpy is far offset by the reduction in NOx emissions of 11,660 tpy. 

111. Conclusion 

NOx is a precurser to the formation of ground-level ozone and the formation of PM2 5, 

both criteria po1lutants. High concentrations of ground-level ozone and particulate matter are 

serious threats to public health and welfare. Significant reductions ofNOx, as well as carbon 

dioxide, particulates, sulfur dioxide, carbon monoxide and mercury \Vill be achieved by 

retiring the coal-fired boilers and convt!rting the generation of electrity to natural gas. The 

conversion to natural gas will result in less smog and acid rain formation and will not create 

coal combustion residuals. 

***** 

For the reasons set forth above, approval does not interfere with any applicable 

requirement concerning attainment and reasonable further progress, or any other applicable 

requirement as required by Section 11 00) of the federal CAA. APCD respectfully requests 

EPA to approve the LG&E Cane Run NOx RACT plan-Amendment 2. 

3 Indiana monitoring sites not included. 
Beverly Banister, D~rcctor 

May 19,2015 

Page 5 ofS 

1 f you have any questions regarding this request or need additional information, please 

contact Paul Aud at (502) 574-7234 or paul.aud@louisvilleky.gov or Stacey Barbro at (502) 

574-5237 or stacey.barbro@louisvilleky.gov. 

Sincerely. 

Keith H. Talley Sr., Director 

Louisville Air Pollution Control District 

cc: Sean Alteri, Kentucky Division for Air Quality 

Lynorae Benjamin, US EPA, Region 4 

Rachael Hamilton, APCD 

Paul Aud, APCD