From: West, Jeffrey L

To: Kordzi, Joe

Subject: RE: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Date: Tuesday, September 01, 2015 3:21:19 PM

Attachments: Xcel Response to EPA Information Request on EPA Proposed Rule on Texas Regional Haze - Sixth Request

 09012015.pdf

Joe:

Please find attached our response to your latest round of questions.  Please include in the docket

and let me know if there are any further questions.

Jeff West

Xcel Energy | Responsible By Nature

Director, Environmental Services

1800 Larimer Street, Suite 1300, Denver, CO 80202

P: 303-571-2762 C: 806-570-8914 F: 303-294-2859

E: Jeffrey.L.West@xcelenergy.com

From: Kordzi, Joe [mailto:Kordzi.Joe@epa.gov] 

Sent: Saturday, August 29, 2015 7:19 PM

To: West, Jeffrey L

Subject: RE: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Jeff,

I’m a little confused by some statement you folks made on page 30 of the originally submitted

comments.  You state the following:

“In addition, the plant monitors water treatment continuously to maximize the water quality on the

supply side to the cooling cycle so that maximum cycles of concentration can be utilized to limit the

amount of blowdown water on the discharge side of the cooling cycle. Basically, Tolk "reuses" the

water 20 to 25 times before a solubility limit is reached. To maintain the proper chemistry, some of

the

cooling water is blowdown (average of 300-350 GPM) to evaporation ponds. This maximum use of

existing water means the total plant water "makeup" (water required for all of plant operations

including

cooling tower evaporation, boiler water, auxiliary cooling, washdowns, etc.) is much less than other

plants that do not maximize water usage. Even though a dry scrubber sorbent preparation system

could

reuse part of the blowdown as makeup water, the plant would still require additional fresh makeup

water

for the dry scrubber process. As a result, installing dry scrubbers at Tolk would increase the makeup

water intake requirements for the complex by approximately 9-12%.

These increased water requirements are highly significant in light of the critical lack of water in
the region. This additional amount of water is simply not available at the Tolk site. Xcel Energy

estimates adding dry scrubbers would require approximately 1,165 acre/feet per year of water

availability. Over 30 years, as amortized by EPA for this Proposal, additional water requirements

would

be approximately 36,000 acre-feet for operation of the scrubbers. To obtain the additional amount

of

water necessary to support the operation of dry scrubbers, SPS would attempt to purchase

significant

water rights from existing farmers along with a gathering system or look at other costly alternatives.

Based on the historical cost of water rights in the area, this is an additional cost of approximately

$40

million that was not included in EPA's cost estimates. This is also assuming that these water rights

are

available. The acquisition of these water rights may require the purchase of neighboring agricultural

businesses, which could further increase acquisition costs. These costs for additional water rights,

infrastructure or alternatives are not included in EPA's overall cost estimate for dry scrubber

installation. If these costs were added, they would greatly increase the estimated cost of dry

scrubbers at

Tolk and the associated cost per ton of emissions reduction.”

So my questions are: 

1. Are you stating that you believe the total water needed to support SDA is 1,165 acre-feet

per year?

2. Would you explain what is meant by, “To maintain the proper chemistry, some of the

cooling water is blowdown (average of 300-350 GPM) to evaporation ponds.”  Does this

mean you are currently using 300-350 gpm blowdown in your cooling system, or that is the

amount that goes to the pond?

3. How much blowdown water is available, that is not currently being used?

From: West, Jeffrey L [mailto:jeffrey.l.west@xcelenergy.com]

Sent: Friday, August 28, 2015 2:36 PM

To: Kordzi, Joe

Subject: RE: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Mr. Kordzi:

Attached is the response to your question.  Please let us know if you have any additional questions.

Jeff West

Xcel Energy | Responsible By Nature

Director, Environmental Services

1800 Larimer Street, Suite 1300, Denver, CO 80202

P: 303-571-2762 C: 806-570-8914 F: 303-294-2859
E: Jeffrey.L.West@xcelenergy.com

From: Kordzi, Joe [mailto:Kordzi.Joe@epa.gov] 

Sent: Friday, August 28, 2015 12:15 PM

To: West, Jeffrey L

Subject: RE: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Jeff,

In your 8/20/15 letter, you stated:

Tolk Station employs activated carbon injection on both units to comply

with the mercury standards under the Mercury and Air Toxics Standards (MATS). This system

is

composed of the pneumatic transport of brominated active carbon to lances injected in the

ductwork

downstream of the preheater. The brominated activated carbon is stored in silos on site. Feed

rates are

adjusted based on compliance with the mercury limits under MATs.

Where in relation to the baghouse are these lances located?  Are you still selling your flyash for

concrete or other uses?  Does the injection of the ACI impact those sales and if so are you taking

steps to deal with that?  Thanks.

From: West, Jeffrey L [mailto:jeffrey.l.west@xcelenergy.com]

Sent: Friday, August 28, 2015 11:51 AM

To: Kordzi, Joe

Subject: RE: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Mr. Kordzi:

I have attached a revised Attachment 1 from our August 26, 2015 response as you have requested. 

Please let us know if you need any additional information.

Jeff West

Xcel Energy | Responsible By Nature

Director, Environmental Services

1800 Larimer Street, Suite 1300, Denver, CO 80202

P: 303-571-2762 C: 806-570-8914 F: 303-294-2859

E: Jeffrey.L.West@xcelenergy.com

From: Kordzi, Joe [mailto:Kordzi.Joe@epa.gov] 

Sent: Friday, August 28, 2015 9:08 AM
To: West, Jeffrey L

Subject: RE: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Jeff,

I can’t seem to be able to pick out the shaded area that indicates the SPS water rights in Attachment

1.  Would it be possible to get another copy of this map with the area outlined in yellow, while

retaining the locations of the wells and pipelines?

From: West, Jeffrey L [mailto:jeffrey.l.west@xcelenergy.com]

Sent: Wednesday, August 26, 2015 9:21 PM

To: Kordzi, Joe

Cc: Metcalf, Dean R

Subject: RE: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Mr. Kordzi:

Please find attached our response to your inquiry below.  As indicated in the response letter, I would

like to formally request that this document be added to the docket.  Please let me know if you have

any questions.

Jeff West

Xcel Energy | Responsible By Nature

Director, Environmental Services

1800 Larimer Street, Suite 1300, Denver, CO 80202

P: 303-571-2762 C: 806-570-8914 F: 303-294-2859

E: Jeffrey.L.West@xcelenergy.com

From: Kordzi, Joe [mailto:Kordzi.Joe@epa.gov] 

Sent: Saturday, August 22, 2015 7:10 PM

To: West, Jeffrey L

Cc: Metcalf, Dean R

Subject: RE: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Jeff,

Can you provide a map that indicates the locations of the water wells described in your response? 

Do you have a table or spreadsheet that indicates the withdrawal rate of these wells?  Also, pls go to

this link:

http://interchange.puc.state.tx.us/WebApp/Interchange/Documents/43695_194_837256.PDF

See p. 21:

“QUESTION NO. AXM 12-13: [Decommissioning] - Please identify the quantity of water rights directly
owned or where the Company has a financial right to resale or lease water rights for some period of

time in the future at each of the Company's power plants. For each water right where the Company

has ownership or financial interest in water rights, provide the current expected market value for

each such water right and the basis for such estimation.”

Note the table provided indicates that Tolk/Plant X has access to an estimated greater than 140,000

acre-feet of recoverable water.

How does this figure align with the information you provided?  Where is this water located and is

any of it outside of the approximately 47,000 acre area discussed earlier?  Is any of this water being

sold?

Thanks.

From: West, Jeffrey L [mailto:jeffrey.l.west@xcelenergy.com]

Sent: Thursday, August 20, 2015 4:25 PM

To: Kordzi, Joe

Subject: Response to information Request - Tolk Station - Docket No. EPA-R06-OAR-2014-0754

Joe:

Please find attached a response to your questions regarding water use/availability and mercury

controls at Tolk Station.  Additionally, in this letter we have formally requested that this letter to be

added to the docket.  A hard copy will follow via US mail.  Please let me know if you have any

questions.

Jeff West

Xcel Energy | Responsible By Nature

Director, Environmental Services

1800 Larimer Street, Suite 1300, Denver, CO 80202

P: 303-571-2762 C: 806-570-8914 F: 303-294-2859

E: Jeffrey.L.West@xcelenergy.com