ENTERGY LOUISIANA, LLC 

ENTERGY TEXAS, INC. 

COMMENTS ON EPA’S RESPONSE AND TECHNICAL SUPPORT DOCUMENT FOR 

THE 2010 SULFUR DIOXIDE NATIONAL AMBIENT AIR QUALITY STANDARD 

AREA DESIGNATION FOR CALCASIEU 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 (“SO2”) National Ambient Air Quality Standards (“NAAQS”). The EPA 

Response further identifies the Agency’s intended designation of certain specific areas1 as either 

nonattainment, unclassifiable/attainment, or unclassifiable for the 2010 SO2 NAAQS, and makes 

available the Technical Support Documents (“TSD”) supporting the intended designations. The 

EPA Response invited input and comments from interested parties regarding the EPA’s intended 

designations in order to gather additional information before making final designations for the 

specific area addressed in the EPA Response. 

 The EPA Response specifically identifies Calcasieu Parish, Louisiana, as an area which 

the Agency intends to designate as unclassifiable, which intended designation represents a 

modification of the recommendation by the Louisiana Department of Environmental Quality 

(“LDEQ”). Entergy Louisiana, LLC, and Entergy Texas, Inc., (collectively, “Entergy”) own and 

operate facilities located in Calcasieu Parish, 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 interest in the EPA Response and the proposed 

designations contained therein. Accordingly, 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. 

 

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 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 SO2 NAAQS based 

on the most recent three calendar years of certified monitored 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 SO2 or (ii) more than 26,000 tons of SO2 with 

an annual average emission rate of at least 0.45 pounds of SO2/mmBTU. See Sierra Club v. McCarthy, No. 3-13-cv3953 (SI) (N.D. Cal. Mar. 2, 2015). 
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 Entergy supports the recommendation by LDEQ to designate Calcasieu Parish, 

Louisiana, as in attainment for the 2010 SO2 NAAQS, and urges EPA to adopt the same. In 

conjunction with its designation recommendation, LDEQ submitted an air quality modeling 

analysis for Calcasieu Parish to EPA on September 17, 2015, which concluded the SO2

concentration in Calcasieu Parish is below the 2010 SO2 NAAQS. Although the Louisiana TSD 

presents a number of technical concerns regarding the September 2015 air quality modeling 

analysis, it does not reflect that any additional modeling analysis 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 quality modeling analysis 

concerning the area of analysis, meteorology and surface characteristics and background 

concentrations are trivial and do not justify modification of LDEQ’s attainment recommendation, 

particularly considering that no alternate analysis is available in the public record of EPA’s 

proposed designation. Indeed, many of the alleged 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 designation recommendation document reflects 

that LDEQ considered data from three existing ambient air monitors located in Calcasieu Parish 

that comprise over 99.5% of all SO2 emissions in Calcasieu Parish; and that all three monitors 

are in compliance with the 2010 SO2 NAAQS. Calcasieu Parish Support Document, at .3-5 

(Sept. 18, 2015). LDEQ’s recommendation document and supporting modeling analysis 

recognize that all three monitors are located in close proximity to the industrial facilities in 

consideration under the proposed designation. EPA’s own Louisiana 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 monitored data in establishing background 

concentrations based on the monitor’s “close proximity” to Entergy’s Nelson facilities (Id. at 

28), while simultaneously asserting that the monitor is “not representative of the maximum from 

Nelson facilities and other cumulative sources” Id. at 21. In consideration of the entirety of the 

monitoring data in close proximity to the industrial sources in question and 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 SO2 NAAQS. 

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

reflect that the most recent design value based on data collected between 2012 and 2014 for the 

Westlake monitor was 35 ppb, well below the 2010 SO2 NAAQS. See Louisiana TSD at 30. 

This monitor is located approximately 2.5 km south 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 the Westlake monitor to the 

Nelson facilities, EPA concludes that the Westlake monitor’s design value demonstrates that the 

two Nelson facilities likely are not causing exceedances of the 2010 SO2 NAAQS and are not the 

primary contributors to EPA’s predicted maximum concentrations of SO2. Id. Given these 

findings, EPA should conclude that SO2 emissions reductions at the Nelson facilities are not 
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warranted or necessary to achieve a designation of attainment for Calcasieu Parish for the 2010 

SO2 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 Calcasieu Parish of unclassifiable for the 2010 

SO2 NAAQS, EPA should allow the State additional time to evaluate additional modeling 

information and monitoring data for the purpose 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 deadline for air quality 

characterization under the Data Requirements Rule (“DRR”) where 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 unclassifiable on July 2, 2016, States and affected 

sources will need additional time to further characterize air quality in such areas, and EPA 

should not arbitrarily impose an unrealistic deadline for completing the additional evaluation at 

the expense of the public and affected sources. 

III. CONCLUSION

 Entergy appreciates the opportunity to review the EPA Response and the Louisiana TSD 

and to provide comments and information regarding 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 for Calcasieu Parish, Louisiana. 

 Respectfully submitted, 

 

 Kelly McQueen 

 Asst. General Counsel-Environmental 

 Entergy Services, Inc.