ENTERGY LOUISIANA, LLC ENTERGY TEXAS, INC.

COMMENTS ON EPA’S RESPONSE AND TECHNICAL SUPPORT DOCUMENT FOR

THE 2010 SULFUR DIOXIDE NATIONAL AMBIENT AIR Q UALITY STANDARD

AREA DESIGNATION FOR CAL CASIEU PARISH, LOUISIANA

EPA-HQ-OAR-2014-0464

______________________________________________________________________________

I. INTRODUCTION

On March 1, 2016, the U.S. Environmental Protection Agency (“EPA” or “Agency”) published in the Federal Register , at 81 Fed. Reg. 10,563, the Public Notice of Availability for the Agency’s responses to State designation recommendations (“EPA Response”) for the 2010 Sulfur Dioxide (“SO 2 ”) National Ambient Air Quality Standards (“NAAQS”). The EPA Response further identifies the Agency’s inte nded designation of ce rtain specific areas 1 as either
nonattainment, unclassi fiable/attainment , or unclassifiable for the 2010 SO 2 NAAQS, and makes available the Technical Support Documents (“TS D”) supporting the intended designations. The EPA Response invited input and comments from in terested parties regard ing the EPA’s intended designations in order to gather additional info rmation before making final designations for the specific area addressed in the EPA Response.

The EPA Response specifically identifies Calc asieu Parish, Louisiana, as an area which the Agency intends to designate as unclassifiable , which intended desi gnation represents a modification of the recommendation by the Louisi ana Department of E nvironmental Quality (“LDEQ”). Entergy Louisiana, LLC, and Entergy Texas, Inc., (collectively, “Entergy”) own and operate facilities located in Calcasieu Paris h, Louisiana, which are identified in the EPA Response and TSD as the “Nelson facilities.” See Louisiana TSD at 20-21. Given its operations in this area, Entergy maintains a strong in terest in the EPA Response and the proposed designations contained therein. Accordingl y, Entergy submits these comments on the EPA Response and TSD for Louisiana.

Entergy appreciates EPA’s consideration of these comments and urges EPA to adopt the recommendations for area designations submitted by the State of Louisiana.

II. CALCASIEU PARISH, LOUISIANA

1. The Uncontradicted Modeling Analysis Supports LDEQ’s Attainment

Recommendation for Calcasieu Parish.

1 The specific areas in EPA’s current round of designations, to be completed by July 2, 2016 pursuant to a Consent Decree, address two groups of areas : (1) areas that have newly monitored violations of the 2010 SO 2 NAAQS based on the most recent three calendar years of certified monitore d ambient air quality data, and (2) areas that contain any stationary source that had not been announced as of March 2, 2015, for retirement and that according to EPA’s Air Markets Database emitted in 2012 either (i) more than 16,000 tons of SO 2 or (ii) more than 26,000 tons of SO 2 with an annual average emission rate of at least 0.45 pounds of SO 2 /mmBTU. See Sierra Club v. McCarthy , No. 3-13-cv3953 (SI) (N.D. Cal. Mar. 2, 2015).2 Entergy supports the recommendation by LDEQ to designate Calcasieu Parish, Louisiana, as in attainment for the 2010 SO 2 NAAQS, and urges EPA to adopt the same. In conjunction with its designation recommendati on, LDEQ submitted an air quality modeling analysis for Calcasieu Parish to EPA on September 17, 2015, which concluded the SO 2 concentration in Calcasieu Parish is below the 2010 SO 2 NAAQS. Although the Louisiana TSD presents a number of technical concerns re garding the September 2015 air quality modeling analysis, it does not reflect th at any additional modeling anal ysis has been conducted or considered by EPA in proposing to modify LDEQ’s attainment recommendation. The impact of the alleged technical errors or discrepancies in the September 2015 air qu ality modeling analysis concerning the area of analysis, meteorology and surface characte ristics and background concentrations are trivial and do not justify m odification of LDEQ’s a ttainment recommendation, particularly considering that no alternate analysis is available in the public record of EPA’s proposed designation. Indeed, many of the alle ged technical errors regarding meteorology and surface data are not prohibited by EPA’s Modeling Technical Assistance Document and have been accepted by LDEQ and EPA in previous New Source Review modeling analyses.

Furthermore, LDEQ’s September 2015 de signation recommendation document reflects that LDEQ considered data from three existing ambient air monitors located in Calcasieu Parish that comprise over 99.5% of all SO 2 emissions in Calcasieu Parish; and that all three monitors are in compliance with the 2010 SO 2 NAAQS. Calcasieu Parish Support Document, at .3-5 (Sept. 18, 2015). LDEQ’s recommendation doc ument and supporting modeling analysis recognize that all three m onitors are located in close proximity to the industrial facilities in consideration under the proposed designation. EPA’s own Louisian a TSD includes an apparent contradiction with respect to the Westlake monitor

― which shows a monitored concentration of 47% of the NAAQS

― by encouraging the use of the monito red data in esta blishing background

concentrations based on the monitor’s “close proximity” to Entergy’s Nelson facilities ( Id. at 28), while simultaneously asserting that the monito r is “not representative of the maximum from

Nelson facilities and other cumulative sources” Id. at 21. In consideratio n of the entirety of the monitoring data in close proximity to the industr ial sources in question a nd the uncontradicted air quality modeling analysis submitted by LDEQ , EPA should affirm LDEQ’s attainment recommendation for Calcasieu Parish, Louisiana.

2. The Monitored Design Values Demonstrate that the Nelson Facilities Are Not Causing Exceedances of the 2010 SO 2 NAAQS.

Both the uncontradicted 2015 air quality modeling analysis and EPA’s Louisiana TSD

reflect that the most recent design value based on data coll ected between 2012 and 2014 for the Westlake monitor was 35 ppb, well below the 2010 SO 2 NAAQS. See Louisiana TSD at 30. This monitor is located approximately 2.5 km sout h of the two Nelson facilities, and 10 km north of the area where the Louisiana TSD alleges the greatest imipacts of SO2 emissions are expected based on EPA’s grouping analysis. Id. Based on the proximity of th e Westlake monitor to the Nelson facilities, EPA concludes that the Westlake monitor’s design value demonstrates that the two Nelson facilities likely are no t causing exceedances of the 2010 SO 2 NAAQS and are not the primary contributors to EPA’s pred icted maximum concentrations of SO 2

. Id. Given these findings, EPA should conclude that SO 2 emissions reductions at th e Nelson facilities are not3 warranted or necessary to achieve a designation of attainment for Calcasieu Parish for the 2010

SO 2 NAAQS.

3. EPA Should Allow Additional Time to Evaluate Additional Data After July 2, 2016, if EPA Makes a Final Designation of Unclassifiable for Calcasieu

Parish.

Should EPA make a final designation for Cal casieu Parish of unclassifiable for the 2010 SO2 NAAQS, EPA should allow the State additi onal time to evaluate additional modeling information and monitoring data for the pur pose of determining how LDEQ will further characterize air quality for Calcasieu Parish. It is wholly inequitable and incongruent to require the State and affected sources to comply with the July 1, 2016 d eadline for air quality

characterization under the Data Requirements Rule (“DRR”) wh ere EPA will not finalize the area designation which triggers applicability of the DRR until July 2, 2016. 80 Fed. Reg. 51,052 (Aug. 21, 2015). For areas designated as unclassi fiable on July 2, 2016, States and affected

sources will need additional time to further ch aracterize air quality in such areas, and EPA should not arbitrarily impose an unrealistic dead line for completing the additional evaluation at the expense of the public and affected sources.

III. CONCLUSION

Entergy appreciates the opportunity to revi ew the EPA Response and the Louisiana TSD and to provide comments and information regardi ng the same. Review and analysis of the full record of modeling analysis, monitor data and other information submitted by the State of Louisiana and uncontradicted by EPA confirms that EPA should accept LDEQ’s attainment recommendation for the 2010 SO2 NAAQS fo r Calcasieu Parish, Louisiana.

Respectfully submitted,

Kelly McQueen

Asst. General Counsel-Environmental Entergy Services, Inc.