1 

### Medina, Dayana

From: Medina, Dayana

Sent: Wednesday, February 19, 2014 4:12 PM

To: Pettyjohn, Mary

Subject: RE: Entergy Lake Catherine

Hi Mary,

Thank you for forwarding Entergy’s response. We appreciate ADEQ and Entergy’s willingness to work with us to help

address our concerns regarding NOx BART for this unit. We believe the NOx emission limit Entergy is proposing of 0.22

lb/MMBtu on a 30

‐ day rolling average basis for Lake Catherine Unit 4 is reasonable. Please let me know if ADEQ would

like to discuss this matter with Region 6.

Thank you,

Dayana Medina

U.S. Environmental Protection Agency, Region 6

Multimedia Planning and Permitting Division

Air Planning Section (6PD

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214

‐ 665

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From: Pettyjohn, Mary [ mailto:PETTYJOHN@adeq.state.ar.us ]

Sent: Wednesday, February 12, 2014 7:35 AM

To: Medina, Dayana

Subject: FW: Entergy Lake Catherine

Good morning Dayana,

Here is Entergy

– Lake Catherine’s response.

Best regards,

Mary

From: Triplett, David [ mailto:dtripl1@entergy.com ]

Sent: Tuesday, February 11, 2014 2:05 PM

To: Pettyjohn, Mary; JOHNSON, GEORGE

Subject: RE: Entergy Lake Catherine

Mary,

We have reviewed the proposals from EPA Region 6, and appreciate the willingness of both ADEQ and EPA to work with

us to establish a BART limit for Lake Catherine Unit 4 which preserves operational flexibility for the unit.

Of the three proposals, we prefer the general approach of option 2) which utilizes a 30

‐ day averaging time for the limit

without introducing a bifurcated limit as in option 3). However, we remain concerned that the unit may not be able to

meet the proposed limit of 0.20 lb/MMBtu for all 30

‐ day averaging periods following installation of BOOS.

To address EPA’s concerns while maintaining operational flexibility for the unit, Entergy would be willing to propose a

NOx limit for LC4 of 0.22 lb/MMBtu (30

‐ day average) as BART. If ADEQ and EPA are willing to consider this emission rate

as BART for this unit, please let us know and we will prepare a revised FFA reflective of this emission rate.

If you have any questions or concerns regarding this proposal, please let us know.2 David Triplett, P.E.

Air Lead, Arkansas Environmental Support

Entergy Services, Inc.

8-750-4030 (internal) | (501) 377-4030 (office) | (501) 650-1752 (cell)

From: Pettyjohn, Mary [ mailto:PETTYJOHN@adeq.state.ar.us ]

Sent: Thursday, December 19, 2013 3:34 PM

To: Triplett, David; JOHNSON, GEORGE

Subject: FW: Entergy Lake Catherine

Hi David,

Please see EPA Region 6 comments on Lake Catherine. Also, the Region 6 RH team will be out of the office starting

tomorrow and will return Jan 6, 2014.

I will be out of the office tomorrow.

The office will be closed Dec 24 th and 25 th

. I will not out of the office the 26 th and 27 th

.

Mary

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

Sent: Thursday, December 19, 2013 2:33 PM

To: Pettyjohn, Mary

Cc: Donaldson, Guy; Feldman, Michael

Subject: Entergy Lake Catherine

Hi Mary,

We appreciate the time you have spent with us and Entergy to try and understand the issues involved in setting an

emissions limit for burners out of service (BOOS) for the Lake Catherine facility. Entergy has proposed a limit of 0.24

lb/MMBtu measured on a 30 day rolling average. This limit was based on a 50% reduction off a 0.48 lb/MMBtu

emission rate that was used as a baseline. Based on the information we have gleaned from review of past data, the 0.48

lb/MMBtu emission rate is a maximum daily average that only occurred once during the period 01/01/2001

– 12/31/2003. Despite the rarity of this high load event, we understand the company believes they must be prepared for

the possibility of high load that would result in this potentially higher emission rate.

Our concern is that based on the information we have reviewed and as can be seen in the graph below, a limit of 0.24

lb/million Btu, most of the time, would not even require operation of the BOOS controls because the facility already is

operating below this limit and, as a result, will result in little reduction in NOx.

In an attempt to address our concerns and Entergy’s, we propose three alternatives.

1) A 24 hour daily maximum of 0.24 lb/million Btu. This should provide the company the flexibility to meet the

limit and operate the facility at maximum loads. The limit in turn would insure reductions of emissions on the

highest emissions days.

2) A 30 day rolling average of 0.20 lb/million Btu. Based on our review of the data, such a limit should be

achievable based on 50% reduction in emissions off any 30 day rolling average observed.

3) A bifurcated approach where the facility would have a higher 30 day limit of 0.24 lb/million Btu when the 30

day load was at exceptionally high levels and a lower limit of 0.18 lb/million Btu when the 30 day load was at

more normal levels. This approach would take further discussions with the company to establish the

appropriate load levels for the two limits. Our interest would be that emissions at normal load levels would be

reduced but allowing flexibility for the company to operate at high levels if necessary and still be in compliance.3 We hope that you and the company will find one of these options addresses the concerns that have been raised. Please

let us know if you would like to discuss any of these options further.

Thank you,

Dayana Medina

U.S. Environmental Protection Agency, Region 6

Multimedia Planning and Permitting Division

Air Planning Section (6PD

‐ L)

214

‐ 665

‐ 7241

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