### FW: FW: Determination to update Entergy White Bluff baseline rates Pettyjohn, Mary to: Dayana Medina 08/29/2012 02:30 PM From: "Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us> To: Dayana Medina/R6/USEPA/US@EPA History: This message has been forwarded. 3 attachments

Hi Dayana, Here is what will be discussed. Mary From: Jeremy Jewell [ mailto:JJewell@trinityconsultants.com] Sent: Tuesday, August 28, 2012 7:31 PM To: Pettyjohn, Mary; Brown, Derrick; Rheaume, Thomas Cc: kmcque1@entergy.com; Tracy Johnson; Chad Wood; Molly Goldstein; Kasi Dubbs; Kara Gerlach Subject: Re: FW: Determination to update Entergy White Bluff baseline rates Mary et. al., I don't suppose there is any guarantee that the lower sulfur mines will always be used. That is what is being used now, and therefore that is the basis from which any visibility improvement will occur in actuality. Tom's comment, "Is this going to make any difference in the final (BART) analysis?" is certainly appropriate. From what we can tell, the selection of the baseline period is not going to change the ultimate BART determinations. Having said that, we have already completed much of the modeling based on the new ('09-'11) baseline period. Right or wrong, we assumed this would be preferred. So changing back to '01-'03 would cause a substantial amount of re-modeling. Your idea of a call with EPA next week is probably best. We certainly want everyone to agree before we go too much further. In the meantime we offer the following additional information, including your request for a comparison of max. daily emissions between the two baseline period possibilities, for your consideration. The below table summarizes the main differencesbetween the two baseline periods : [cid:_1_086EDC80086ED8800002D39886257A69] Ultimately the boilers simply do not operate like they did in 2001-2003 because the boiler efficiency has been improved (affecting both NOX and SO2) and the fuel has changed (really just an SO2 issue). Thus, the 2001-2003 period is not reflective of what now is to be controlled. To us, this type of situation is addressed in the BART guidance - 40 CFR Part 51, Appendix Y, Section IV.D.4.c.

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___ Jeremy W. Jewell | Manager of Consulting Services, Oklahoma OKC: 120 E. Sheridan, Suite 205, Oklahoma City, OK 73104 | 405-228-3292 Tulsa: 1831 E. 71st Street, Suite 118, Tulsa, OK 74136 | 918-877-2742 e-mail: jjewell@trinityconsultants.com< mailto:jjewell@trinityconsultants.com> | e-fax: 918-512-7084

From: "Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us< mailto:PETTYJOHN@adeq.state.ar.us>>
To: "Jeremy Jewell (jjewell@trinityconsultants.com< mailto:jjewell@trinityconsultants.com>)" <jjewell@trinityconsultants.com< mailto:jjewell@trinityconsultants.com>>
Cc: "Rheaume, Thomas" <RHEAUME@adeq.state.ar.us< mailto:RHEAUME@adeq.state.ar.us>>, "Brown, Derrick" <brownd@adeq.state.ar.us< mailto:brownd@adeq.state.ar.us>>
Date: 08/28/2012 12:26 PM Subject: FW: Determination to update Entergy White Bluff baseline rates

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Hi Jeremy,I apologize for not sending this to you earlier. The questions are the same EPA has. Tom and I believe it is okay to change the parameters and baseline emissions for Domtar but still have reservations about Entergy White Bluff. Before you run the model, please reply to the concerns below and we will get back to you right away. Thanks, Mary From: Rheaume, Thomas Sent: Monday, August 27, 2012 2:30 PM To: Pettyjohn, Mary Cc: Brown, Derrick Subject: RE: Determination to update Entergy White Bluff baseline rates Since there are multiple mines involved, what guarantee is there that these lower sulfur containing mines will always be used? Also this is going to raise a lot of questions about differences from the first analysis. Is this going to make any difference in the final (BART) analysis?

Thomas Rheaume Permit Branch Manager Arkansas Department of Environmental Quality Air Division 5301 Northshore Drive North Little Rock, AR 72118-5317 501 682 0762 Phone 501 682 0880 Fax From: Jeremy Jewell [ mailto:JJewell@trinityconsultants.com]<mailto:[ mailto:JJewell@trinityconsultants.com]> Sent: Monday, August 27, 2012 12:08 PM To: Pettyjohn, Mary Cc: Rheaume, Thomas Subject: Fw: Determination to update Entergy White Bluff baseline rates
See below. With this information, do you feel it is reasonable - or even preferred - to use updated baseline emission rates in the BART analysis?

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___Jeremy W. Jewell | Manager of Consulting Services, Oklahoma OKC: 120 E. Sheridan, Suite 205, Oklahoma City, OK 73104 | 405-228-3292 Tulsa: 1831 E. 71st Street, Suite 118, Tulsa, OK 74136 | 918-877-2742 e-mail: jjewell@trinityconsultants.com< mailto:jjewell@trinityconsultants.com> | e-fax: 918-512-7084 ----- Forwarded by Jeremy Jewell/Trinity Consultants on 08/27/2012 12:05 PM ----- From: "JOHNSON, GEORGE" <GJOHNS6@entergy.com< mailto:GJOHNS6@entergy.com>>
To: Jeremy Jewell <JJewell@trinityconsultants.com< mailto:JJewell@trinityconsultants.com>>
Cc: Molly Goldstein <MGoldstein@trinityconsultants.com< mailto:MGoldstein@trinityconsultants.com>>, "McQueen, Kelly" <kmcque1@entergy.com< mailto:kmcque1@entergy.com>>
Date: 08/27/2012 11:01 AM Subject: RE: Determination to update Entergy White Bluff baseline rates

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Yes, we did start getting coal from different mines. White Bluff had a long term (20 year) contract in place with one mine which had expired. This allowed us to expanded our portfolio of suppliers and some of these mines have lower sulfur coal than the original mine. From: Jeremy Jewell [ mailto:JJewell@trinityconsultants.com] Sent: Friday, August 24, 2012 9:53 AM To: JOHNSON, GEORGE Cc: Molly Goldstein; McQueen, Kelly Subject: Fw: Determination to update Entergy White Bluff baseline ratesSee question from ADEQ.

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___ Jeremy W. Jewell | Manager of Consulting Services, Oklahoma OKC: 120 E. Sheridan, Suite 205, Oklahoma City, OK 73104 | 405-228-3292 Tulsa: 1831 E. 71st Street, Suite 118, Tulsa, OK 74136 | 918-877-2742 e-mail: jjewell@trinityconsultants.com< mailto:jjewell@trinityconsultants.com> | e-fax: 918-512-7084 ----- Forwarded by Jeremy Jewell/Trinity Consultants on 08/24/2012 09:51 AM ----- From: "Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us< mailto:PETTYJOHN@adeq.state.ar.us>>
To: "Jeremy Jewell (jjewell@trinityconsultants.com< mailto:jjewell@trinityconsultants.com>)" <jjewell@trinityconsultants.com< mailto:jjewell@trinityconsultants.com>>
Date: 08/24/2012 09:50 AM Subject: FW: Determination to update Entergy White Bluff baseline rates

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H Jeremy, Tom has some questions concerning Trinity's rationale for changing the baseline emissions. They are shown below. Thank you, Mary From: Rheaume, Thomas Sent: Friday, August 24, 2012 9:11 AMTo: Pettyjohn, Mary; Brown, Derrick Subject: RE: Determination to update Entergy White Bluff baseline rates I would like to know why it changed. Did they start getting coal from a different mine? Do they even know why?
Thomas Rheaume Permit Branch Manager Arkansas Department of Environmental Quality Air Division 5301 Northshore Drive North Little Rock, AR 72118-5317 501 682 0762 Phone 501 682 0880 Fax From: Pettyjohn, Mary Sent: Friday, August 24, 2012 6:47 AM To: Rheaume, Thomas; Brown, Derrick Subject: FW: Determination to update Entergy White Bluff baseline rates Tom and Derrick, I would like your opinion on the below rationale to use different baseline emissions before I present it to the group and evidentially EPA. Thanks, Mary From: Jeremy Jewell [ mailto:JJewell@trinityconsultants.com]<mailto:[ mailto:JJewell@trinityconsultants.com]> Sent: Thursday, August 23, 2012 7:25 PM To: Pettyjohn, Mary Cc: JOHNSON, GEORGE; kmcque1@entergy.com< mailto:kmcque1@entergy.com>; Chad Wood; Molly Goldstein Subject: Re: Determination to update Entergy White Bluff baseline rates Mary, Molly's email below inadvertently left out a third change that resulted in substantially less emissions in recent years compared to the original baseline. Beginning in 2007 the sulfur content of the coal utilized at the facility decreased compared to previous years. All of this points to a real difference in operations/emissions between now and then, and our conclusion is that the 2001-2003 time period is not representative of current (and thus future, post-BART) operations. Thanks,

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___Jeremy W. Jewell | Manager of Consulting Services, Oklahoma OKC: 120 E. Sheridan, Suite 205, Oklahoma City, OK 73104 | 405-228-3292 Tulsa: 1831 E. 71st Street, Suite 118, Tulsa, OK 74136 | 918-877-2742 e-mail: jjewell@trinityconsultants.com< mailto:jjewell@trinityconsultants.com> | e-fax: 918-512-7084 From: Molly Goldstein/Trinity Consultants
To: "Pettyjohn, Mary" <PETTYJOHN@adeq.state.ar.us< mailto:PETTYJOHN@adeq.state.ar.us>>
Cc: kmcque1@entergy.com<mailto:kmcque1@entergy.com>, "JOHNSON, GEORGE" <GJOHNS6@entergy.com< mailto:GJOHNS6@entergy.com>>, Chad Wood (wood@gill-law.com<mailto:wood@gill-law.com>) <wood@gill-law.com<mailto: wood@gill-law.com>>, Jeremy Jewell/Trinity Consultants@TCI_Dallas
Date: 08/23/2012 05:47 PM Subject: Determination to update Entergy White Bluff baseline rates

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Entergy White Bluff and Trinity Consultants have reviewed the baseline rates from 2001-2003 that were used in the original visibility modeling analysis. While we agree with the methodology of SO2 and NOx emission rates representing the highest actual 24-hour emission rates, the current operation of the boilers warrants that the baseline emission rates be updated so that they reflect a more realistic estimate of emissions. See BART guidance, Per 40 CFR Part 51, Appendix Y, Section IV.D.4.c. In 2006 Entergy completed the addition of a neural net system. In that same year extensive boiler tuning occurred and these two projects combined loweredpollutant emission rates, especially for SO2
. Table 1-1 summarizes the emission rates for SO2 for the years before the boiler updates, 2001-2006, as well as the most recent years, 2007-2011. As you can see from the table, the average emission rates from the years before the boiler updates were 2,000-3,000 tpy greater per boiler than the most recent years. Table 1-1: Summary of Annual SO2 Emission Rates from Unit 1 and Unit 2 at Entergy White Bluff, 2001-2006 and 2007-2011 [cid:_1_086FC7C0086FBE180002D39886257A69] BART guidance, Per 40 CFR Part 51, Appendix Y, Section IV.D.4.c states, "The baseline emissions rate should represent a realistic depiction of anticipated annual emissions for the source. In general, for the existing sources subject to BART, you will estimate the anticipated annual emissions based upon actual emissions from a baseline period. When you project that future operating parameters (e.g., limited hours of operation or capacity utilization, type of fuel, raw materials or product mix or type) will differ from past practice, and if this projection has a deciding effect in the BART determination, then you must make these parameters or assumptions into enforceable limitations. In the absence of enforceable limitations, you calculate baseline emissions based upon continuation of past practice." In order to represent realistic anticipated annual emissions, Entergy is proposing to use the 2009-2011 emission rates based on 2009-2011 continuous emissions monitoring system (CEMS) data. Using the higher emission rates from 2001-2003 would not show the true emissions reductions from the proposed BART control technology. Moreover, using the higher 2001-2003 emission rates would show greater improvement than would occur in actuality. Thus, updating the emissions to be based on recent years that more accurately represent current, normal operation is an approach which better reflects compliance with the regulations as compared to the alternative. Molly Hathaway Goldstein │ Senior Consultant │ mgoldstein@trinityconsultants.com │ (913) 894-4500 Trinity Consultants, Inc. - Kansas City │ 9777 Ridge Drive, Suite 380 │ Lenexa, KS 66219 │ Phone: (913) 894-4500 Subscribe< http://www.trinityconsultants.com/Subscribe/> today to receive Environmental Quarterly< http://www.trinityconsultants.com/EnvironmentalQuarte rly/> by email.

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